The Commodity Futures Trading Commission’s Division of Market Oversight provided guidance to designated contract markets and swap execution facilities on what expenses they might exclude in calculating their requirement to maintain financial resources adequate to cover operating expenses for a one-year period on a rolling basis. Among the expenses DMO said might be excluded are: sales, marketing, business development, product development and recruitment expenses; compensation, taxes and benefit costs for employees whose functions are not necessary to meet regulatory requirements; costs for acquiring and defending patents and trademarks and other intellectual property; and variable commissions a voice-based SEF may pay to its employee-brokers.