The Commodity Futures Trading Commission and the Financial Crimes Enforcement Network (FinCEN) have issued guidance clarifying the application of customer identification program (CIP) regulations to give-up arrangements. The guidance confirms that, in give-up arrangements, only clearing brokers are subject to CIP requirements. The agencies noted that, although an executing broker in a give-up arrangement facilitates trades for a customer, and the give-up arrangement may be governed by a written agreement, it is only the clearing broker that establishes a formal relationship with the customer for the purposes of the customer identification program rule.

http://www.cftc.gov/opa/press07/opa5321-07.htm