FIA has filed comments with the Commodity Futures Trading Commission on proposed rulemaking related to the protection of clearing member funds held by designated clearing organizations. FIA’s letter supports the proposed codification of segregation and additional protections for clearing member property, many of which are in place today at major clearinghouses. However, the letter cautions that the rulemaking is far from sound footing for the CFTC to approve new direct clearing models, such as the leveraged disintermediated clearing model first sought by FTX.