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Commentary by Bob Zwirb

Citigroup Global Markets, Inc., a registered futures commission merchant and provisionally registered swap dealer, agreed to pay a $25 million civil monetary penalty to settle CFTC charges of spoofing and related supervisory failures.

The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") issued two no-action letters regarding FCMs' handling of customer funds, both intended to deal with operational issues. The first letter (14-02) provides time-limited relief as to the situation where a customer makes a single margin transfer that is required to be divided up into two or three separate types of segregated accounts; e.g. , between Part 30 Secured Funds, Section 4d(a)(2) U.S. futures funds and Cleared Swap Funds. An FCM receiving such a single payment may not be able to split the money instantaneous ly between