Pre-Trade Disclosure

Pre-Trade Disclosure

Pursuant to Commodity Futures Trading Commission (“CFTC”) Regulation § 23.431(a)(3)(i), Cargill, Incorporated (“Cargill”) is required to provide a pre-trade mid-market mark (“PTMMM”) to non-swap dealer counterparties, either orally or in writing, prior to entering into a transaction. The PTMMM must not reflect adjustments for credit reserve, hedging, funding, liquidity, profit, or any other costs or adjustments, as mandated by CFTC Regulation § 23.431.

On April 4, 2025, the CFTC issued No-Action Letter 25-09, which provides relief to swap dealers from the obligation to deliver a PTMMM to non-swap dealer counterparties for swap transactions. While this no-action relief remains in effect, Cargill will rely on it and will not provide you with a PTMMM. 

This relief does not impact Cargill’s obligation to provide you with a Daily Mark pursuant to CFTC Regulation § 23.431(d)(2).