Comment Text:
Re: 17 CFR Parts 1, 3, 22, 30 and 140
RIN 3038-AD88: Enhancing Protections Afforded Customers and Customer Funds Held by Futures
Commission Merchants and Derivatives Clearing Operations, “Federal Register” Vol. 77, No. 220,
pages 67866-67971
Dear Ms. Warfield,
As an owner of a GIB who services ag producers on a daily basis, I am concerned that requiring FCM's to take a capital charge for margin calls outstanding more than one day, rather than the current three-day practice will hurt the very people who you are trying to protect. The logical outcome will be that hedgers and others will end up having to keep more funds in their accounts and in turn have more money at risk. FCM's will have no choice but to pass the new burden on to the customers. Some of the recommended changes should help secure customer funds but this particular change would be a step backward. Thank you.
Sincerely,
George Enloe
