Upfront margin verification required - exchanges to monitor EOD and peak client margins with phased compliance and penalties Clearing Corporations shall send multiple intra-day snapshots and client-wise margin files specifying EOD and peak margin obligations; members must report margins collected at EOD and peak during the day. Verification compares EOD obligation against EOD client margin available and peak obligation across snapshots against client peak margin available; the higher shortfall is used for penalty. Exchanges/Clearing Corporations will verify member books weekly. Adoption of peak-margin comparison is phased, and members must show any remaining peak obligation during the phase is funded from their own funds and not from other clients.
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Provisions expressly mentioned in the judgment/order text.
Upfront margin verification required - exchanges to monitor EOD and peak client margins with phased compliance and penalties
Clearing Corporations shall send multiple intra-day snapshots and client-wise margin files specifying EOD and peak margin obligations; members must report margins collected at EOD and peak during the day. Verification compares EOD obligation against EOD client margin available and peak obligation across snapshots against client peak margin available; the higher shortfall is used for penalty. Exchanges/Clearing Corporations will verify member books weekly. Adoption of peak-margin comparison is phased, and members must show any remaining peak obligation during the phase is funded from their own funds and not from other clients.
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