FIA responds to CFTC proposed rulemaking on FCM separate account margining

22 April 2024

FIA has filed a comment letter with the US Commodity Futures Trading Commission on the regulator’s proposed rulemaking entitled “Regulations to Address Margin Adequacy and to Account for the Treatment of Separate Accounts by Futures Commission Merchants”. FCMs are currently relying on no-action relief that allows them to separately margin accounts of the same beneficial owner.

This rule marks the second attempt by the agency of codifying that relief. FIA’s letter asks the CFTC to codify the relief as written without laying on additional highly prescriptive requirements that limit FCM discretion to risk manage accounts, and that, ultimately, could be operationally burdensome and increase rather than decrease systemic risk.

Read the letter in full.


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