SIFMA AMG Submits Critical Response to JAC Alert on FCM Margin Policies

The Asset Management Group of SIFMA ("SIFMA AMG") submitted a letter to CME Group regarding the potential negative impact of the recently issued Joint Audit Committee ("JAC") alert on SIFMA members, their clients and the asset management business as a whole.

The JAC Regulatory Alert 14-03 was intended to serve as a reminder to futures commission merchants ("FCMs") of certain margin policies related to the receipt of margin deposits and the release of excess margin funds.

SIFMA AMG requested that the JAC withdraw certain provisions of the alert that could impact negatively "beneficial owners" such as institutional investors, registered investment companies, ERISA plans, mutual funds and pension funds. SIFMA AMG requested, if the JAC does not withdraw these provisions, that it amend the alert to allow FCMs to "continue the long established practice of determining margin funds for disbursement separately for each margined account based solely on the transactions associated with that specific account."

See: SIFMA AMG Comment Letter.