SIFMA AMG Submits Comments to the CFTC on Proposed Rules for Enhancing Customer Protections

SIFMA's Asset Management Group ("SIFMA AMG") published the comments it submitted to the CFTC on proposed rulemaking which would enhance protections afforded customers and customer funds held by FCMs and DCOs.

SIFMA AMG strongly endorsed the CFTC's proposal to better protect clients' collateral and improve transparency regarding the FCMs with which they trade. Specifically, SIFMA AMG believes that:

• "FCMs should maintain sufficient margin to cover all margin deficits and maintain segregation between customer accounts - an FCM should not be able to look to one customer's excess margin to cover another's shortfall.
• "The proposed public disclosure requirements will greatly assist our members in choosing FCMs to handle their customers' funds and in holding FCMs accountable to their customers. In particular, SIFMA AMG supports the proposed requirement for FCMs to make publicly available on their websites daily margin segregation calculations together with disclosure documents that would be material to a customer's decision to do business with an FCM. Some relatively small additional measures could be taken to make more information available to the public in a straightforward and easy manner."

Click here to view letter in full (links externally to SIFMA website).Related News and Commentary: Managed Funds Association Submits Comment Letter to CFTC on Proposed Rules for Enhancing Customer Protections (with Lofchie Comment) (February 22, 2013); National Futures Association Submits Comment Letter to CFTC on Proposed Rules for Enhancing Customer Protections (with Lofchie Comment) (February 22, 2013); CFTC Roundtable on Enhancing Protections Afforded Futures Customers (with Lofchie Comment) (February 5, 2013); and Enhancing Protections Afforded to Customers and Customer Funds Held by FCMs and Derivatives Clearing Organizations; Notice of Proposed Rulemaking (CFTC; Fed. Reg. Version) (with Lofchie Comment) (November 14, 2012).