Comments for General CFTC Public Roundtable Discussion on Additional Customer Collateral Protections

General CFTC  Public Roundtable Discussion on Additional Customer Collateral Protections

The CFTC will hold a two-day public roundtable to discuss additional customer collateral protection. The roundtable is to gather public input on a variety of ideas to further protect customers.

All comments on the Day 1 discussions must be identified by RIN number 3038-AD70. All comments on the Day 2 discussions must be identified by RIN number 3038-AD71.

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 Commission has already approved this model for swaps); 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.

Day two of the two-day session will focus primarily on 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 U.S. Securities and Exchange Commission as broker-dealers (BDs); and enhancing the self-regulatory structure.