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The CFTC’s staff issued guidance clarifying how trust companies may be used for daily settlement arrangements, addressing a key operational question for derivatives clearing and custody structures. The move matters because it reduces ambiguity around whether trust-company settlement mechanics satisfy regulatory expectations, potentially easing onboarding for firms that rely on trust charters rather than traditional banks. The guidance is staff-level rather than a formal rule, so its practical impact will depend on how clearinghouses, futures commission merchants and their counsel apply it in existing and new settlement setups. Market participants should watch for follow-up no-action relief or interpretive letters, and for clearing members to adjust daily settlement documentation and trust-company arrangements accordingly.

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