Shipkevich Bitcoin and ICO Attorney
Felix Shipkevich February 23, 2009

In addition to the $20 million required by the CFTC Reauthorization Act of 2008, FDMs with over $10 million in customer liabilities and will be subject to capital requirements that take into account their total liabilities. FDMs that execute customer transactions exclusively via STP will be exempted. In general, the following formula will apply:

Amount required by (a)(i) + .05(customer liabilities – $10,000,000

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