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Case 16-42529 Doc 32 Filed 04/13/16 Entered 04/13/16 11:43:47 Main Document <br />Pg4of21 <br />8. In connection with the Trading and Brokerage Business, the Debtors and their <br />non -Debtor affiliates enter into exchanged -settled transactions on various exchanges, including <br />the Chicago Mercantile Exchange (CME) Group, Intercontinental Exchange (ICE), <br />LCH.Clearnet (formerly known as the London Clearing House), NOS Clearing ASA and <br />Singapore Exchange (SGX). To transact on an exchange, one must be an exchange member. <br />Accordingly, the Debtors generally consummate their exchanged -settled transactions through a <br />clearing agreement (the "ADM Agreement") with ADM Investor Services, Inc. ("ADM"). <br />9. The Debtors' clearing relationship with ADM requires the Debtors to satisfy <br />certain initial and variation margin requirements. Initial margin is the margin that the Debtors <br />are required to pay to be able to initially buy or sell a futures contracts. Variation margin, on the <br />other hand, is the additional margin that ADM requires of its clients based on daily changes in <br />the value of our positions. As of the Petition Date, the Debtors' obligations to ADM were fully <br />collateralized through the posting of cash margin. <br />10. The Debtors desire to continue their Trading and Brokerage Business in the <br />ordinary course post -bankruptcy. In order to continue this business, the Debtors must be free to <br />honor margin calls, if any, associated with their prepetition trades, including margin calls based <br />on post -bankruptcy price movements. In addition, the Debtors must be free, in their business <br />judgment, to enter into new trades, post the associated margin and otherwise transact and <br />perform their obligations under the ADM Agreement and exchange rules. <br />Argument <br />The Debtors Enter Into and Perform Under Cleared Transactions in the Ordinary Course of <br />Business <br />11. The Debtors believe that performing under the ADM Agreement is within the <br />ordinary course of their business and that they can consummate transactions under the ADM <br />M <br />