On September 24, the Division of Clearing and Intermediary Oversight (DCIO) of the Commodity Futures Trading Commission issued Guidance to the Joint Audit Committee regarding regulatory requirements applicable to futures commission merchants (FCMs) with investments in the Reserve Primary Fund (Fund). Pursuant to the Guidance, an FCM may include the investments in the Fund when calculating its capital, segregation and secured amount requirements provided that net asset value (NAV) is reduced to reflect currently available information. The Guidance set forth a declining scale of maximum NAVs: $0.94, effective September 29 and 30; $0.93, effective October 1 and 2; and $0.92, effective October 3 and thereafter. In addition, FCMs must continue to apply the 2% regulatory capital deduction required by CFTC Regulation 1.17 and, if the Fund or the Securities and Exchange Commission reports a lower NAV for the Fund, use that lower value.