Position limits in ETCD require auditor certified underlying exposure beyond set thresholds; AD banks may net and proprietary trade within NOPL. Domestic participants may take intraday long and short positions in ETCDs up to a prescribed exchange threshold without proving underlying exposures; positions beyond that threshold require auditor certified evidence of contracted export/import or other foreign currency exposures and a CFO undertaking that combined OTC and ETCD contracts correspond to actual exposures. Trading members may book contracts up to a specified fraction of eligible limits on that certificate and, with further auditor certification, book up to the eligible limit. AD Category I banks must verify exposures when acting as trading members and may face regulatory action for non compliance.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Position limits in ETCD require auditor certified underlying exposure beyond set thresholds; AD banks may net and proprietary trade within NOPL.
Domestic participants may take intraday long and short positions in ETCDs up to a prescribed exchange threshold without proving underlying exposures; positions beyond that threshold require auditor certified evidence of contracted export/import or other foreign currency exposures and a CFO undertaking that combined OTC and ETCD contracts correspond to actual exposures. Trading members may book contracts up to a specified fraction of eligible limits on that certificate and, with further auditor certification, book up to the eligible limit. AD Category I banks must verify exposures when acting as trading members and may face regulatory action for non compliance.
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