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In Commissioner Scott O'Malia's opening statement before the Technology Advisory Committee, he argued that the reforms currently under consideration fail to close the existing regulatory gap that allows firms to self-report the status, balance and location of the customer funds. O'Malia went on to note that the industry must develop a fully automated technology solution that can verify customer balances held by the FCM, custodial banks and the clearing house. [SL Comment: As an ardent opponent of Dodd-Frank, I note again the irony that FCMs were put forward as a better alternative to tri-party