Staff of the Commodity Futures Trading Commission have authorized a so-called “guaranteed introducing broker” to execute trades on behalf of institutional clients and give them up for clearing at futures commission merchants other than the FCM that guarantees it subject to various conditions. (A G-IB is not required to maintain any of its own regulatory capital; instead it relies on a financial guarantee by one FCM.) Ordinarily, a G-IB is required to carry the accounts of customers it introduces exclusively and fully disclosed at the FCM that guarantees it. In granting this relief, staff noted that the G-IB and its guarantor FCM ultimately share some percentage of common ownership. This relief was granted in a no-action letter issued by the CFTC’s Division of Swap Dealer and Intermediary Oversight.