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Comment for General CFTC Public Roundtable Discussion on Additional Customer Protections

  • From: Dugald Ross
    Organization(s):
    Adina Management Pty Ltd

    Comment No: 58345
    Date: 8/8/2012

    Comment Text:

    My opinion- Extra regulation and accounting costs will only benefit the compliance officers and accounting firms. It will cost more to the FCMs, and customers, be detrimental to the smaller honest firms and will still not provide any extra security as the very nature of fraud and incompetence will mean these extra costs will still not get the end result; Which should be protecting client money.
    It would be better to have these extra costs be effective, and have the exchanges or regulators have properly segregated accounts away from the brokers. (Thought - In this day and age do many of us even need brokers - why cant we self clear directly with an exchange matching system?)
    This seems the only sure way to ensure the client funds are kept secure and are not re-hypothecated in the UK whereby the greatest risks we have are completely out of our control and subject to any number of areas for fraud.
    Thank you.

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