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“Affiliate Conduit Factors” means the four factors identified in the Interpretive Guidance as relevant to considering whether a non-U.S. person is an “affiliate conduit.”
For informational purposes only, the text of the factors (but not the related interpretive material) is reproduced below:
For the full discussion of how the CFTC interprets the term “affiliate conduit” (or alternately “conduit affiliate”), see the Interpretive Guidance at pp. 45358-59.