What the primary record establishes

The CFTC interpreted the requirement for competitive, open, fair and impartial access to designated contract markets. DCMs must end domestic restrictions that violate the requirement within 30 days or explain to the Division of Market Oversight why compliance is infeasible. The release also addresses intermediaries’ access controls on the same timeline. CFTC · Impartial Access Requirements Interpretation ↗

What the distinction changes

Restrictions can sit at the venue, intermediary or technology-provider layer. A customer facing the same error may encounter different policy owners. The commission said it would consider the facts and circumstances of individual cases when considering action.

What to check before drawing a conclusion

Map restrictions to their policy owners and order-routing paths. For a specific market, read the interpretation alongside venue access terms and applicable rules for the intermediary.