CFTC’s Division of Swap Dealer and Intermediary Oversight Provides Guidance on Segregated and Secured Funds Maintained in a Combined Omnibus Account

The CFTC Division of Swap Dealer and Intermediary Oversight (DSIO) released a letter to all futures commission merchants (FCMs) to clarify the record keeping requirements for customer segregated and secured funds maintained in carrying broker omnibus accounts in accordance with CFTC Regulations 1.20 and 30.7. Specifically, the Commission notes that a few FCMs have maintained a single combined customer omnibus account with a carrying FCM for segregated and secured customer trading and assets. The CFTC stated that a single account holding both segregated and secured assets, regardless of memo notation as to allocation of the assets, does not provide a clear delineation of the assets.

Cross-Reference(s): CFTC Reg. 1.20 and 30.7.

View letter in full here (links externally to CFTC website).