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Commentary by Steven Lofchie

Researchers at the Office of Financial Research questioned the application of SEC Form PF as a risk-management instrument. In a published working paper, they recommended capturing additional characteristics on the form to "constrain the range of possible risk profiles more tightly," and suggested revamping the form to better represent complex portfolios.

Commentary by Bob Zwirb

The CFTC Division of Swap Dealer and Intermediary Oversight issued an interpretation of CFTC Rule 30.7(c) ("Treatment of Foreign Futures or Foreign Options Secured Amount"). CFTC Rule 30.7(c) provides that a futures commission merchant ("FCM") must deposit customer funds under the laws and regulations of the foreign jurisdiction that affords the greatest degree of protection to such funds, and provides further that an FCM may not waive any of the protections afforded to customer funds under the laws of that foreign jurisdiction. The interpretation in CFTC Letter 14-110 permits FCMs to deposit