Comment Text:
To my understanding, the purpose of the proposed rule is to stop the misappropriation of customer funds as happened at MF Global and PFG Best.
Increasing FCM margin deposits will not address the issue. In fact, it will make the situation worse. With more funds on deposit, a corrupt FCM CEO (or other staff with regulatory access to the funds), will simply be more tempted to 'misappropriate' the funds.
Any industry will suffer if you increase the barriers to entry; which is the only outcome this rule will have. At a time of depressed volumes, this is not a wise move.
Greed, ego and corruption are the reasons PFG Best and MFG failed. NOT a lack of regulation. Unfortunately, greed and corruption are traits of humanity. CFTC regulation and laws will never eradicate these traits. We can however try and stop them from surfacing through coming down hard on those who choose to behave in such a way. Prosecutions and long jail terms are what is needed for those who have misappropriated money that was not theirs. This will make the greedy and corrupt think twice. This will also restore confidence in our industry. More regulation and higher barriers to entry will not.
