Margin collection requirement: upfront VaR and ELM mandatory; other margins deemed collected if pay in occurs within two working days or by early pay in. TMs and CMs must collect upfront VaR margin and ELM from clients prior to trade; other margins may be collected within a two working day window. If client pay-in (funds or securities) occurs within two working days, or securities are early pay in to the Clearing Corporation, other margins are deemed collected and penalties for short/non-collection do not apply. If pay-in is not made within two working days and other margins are not collected by that time, applicable penalties may be levied. Clearing Corporations continue to collect upfront VaR plus ELM and other margins from TMs/CMs.
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Provisions expressly mentioned in the judgment/order text.
Margin collection requirement: upfront VaR and ELM mandatory; other margins deemed collected if pay in occurs within two working days or by early pay in.
TMs and CMs must collect upfront VaR margin and ELM from clients prior to trade; other margins may be collected within a two working day window. If client pay-in (funds or securities) occurs within two working days, or securities are early pay in to the Clearing Corporation, other margins are deemed collected and penalties for short/non-collection do not apply. If pay-in is not made within two working days and other margins are not collected by that time, applicable penalties may be levied. Clearing Corporations continue to collect upfront VaR plus ELM and other margins from TMs/CMs.
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