CFTC Regulation 1.73 affects IBs and FCMs that execute orders for customers. Thus IBs who execute give-up orders and bunched orders must adopt risk management procedures. This new regulation has been in existence since June 2013. 1.73 came about from Dodd-Frank and requires clearing FCMs and executing firms to establish risk based limits for customer and prop accounts based on position size, order size, margin requirements, etc. It also requires the clearing FCM that is not serving as the executing firm to enter into an agreement that requires the clearing FCM to establish risk based limits for the customer and…