Customer Protection Regulation - Comment Letter - LCH.Clearnet - January 25, 2013
|Proposal Date||Comment Deadline||Final Rule Approved||Effective Date|
|November 14, 2012||February 15, 2012||October 30, 2013||January 13, 2014|
Enhancing Protections Afforded Customers and Customer Funds Held by FCMs and DCOs
January 25, 2013
In the comment letter, LCH.Clearnet recommends the consideration of alternative approaches for routine access to account balances. LCH suggests following the lead of the NFA in utilizing third party audit confirmation.
Also, LCH is concerned that certain residual interest rules will have unintended consequences, such as giving FCMs an incentive to hold less of a capital buffer at the DCO in favor of holding excess capital at the FCM level.