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Additional Customer Collateral Protections - CFTC
February 24, 2012
The CFTC seeks to maximize customer safety in the commodities and futures markets by requiring additional customer collateral protection. Toward that end, the Commission will hold a 2-day public roundtable, where it hopes to garner support for its plan, and gather public input on a variety of ideas that might contribute toward building "a better mousetrap."
Agenda for the Roundtable. Day one discussions will focus on issues related to the advisability and practicality of implementing the legal segregation with operational commingling (LSOC) model as the segregation model for collateral posted by futures customers - the CFTC already has approved this model for swaps. Additional topics include:
- alternative models for the custody of customer collateral;
- enhancing futures commission merchant (FCM) controls over the disbursement of customer funds deposited for trading on U.S. futures markets;
- increasing transparency surrounding an FCM’s holding and investment of customer funds; and,
- lessons learned from commodity brokerage bankruptcy proceedings.
- the protection of customer funds deposited with FCMs for trading on foreign futures markets;
- particular issues associated with entities dually registered with the CFTC as FCMs and the SEC as broker-dealers; and,
- enhancing the self-regulatory structure.

