Futures Commission Merchant Regulation - Comment Letter - Managed Funds Association - August 8, 2011

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Dodd-Frank Timeline, Protection of Cleared Swaps Customer Contracts and Collateral, Commodity Broker Bankruptcy Provisions
Final Rule Issue Effective Date Compliance Date
February 7, 2012 April 9, 2012 November 13, 2012

Note: Subsequent to the bankruptcy of futures commission merchant MF Global in October 2011, MFA submitted a follow-up letter to the CFTC regarding this rulemaking. This letter can be found HERE.

Protection of Cleared Swaps Customer Contracts and Collateral; Conforming Amendments to the Commodity Broker Bankruptcy Provisions
August 8, 2011

From the comment letter:

"The Complete Legal Segregation Model provides superior customer collateral protection when compared to the Legal Segregation with Recourse Model and the Futures Model. Unlike the Complete Legal Segregation Model, both the Legal Segregation with Recourse Model and the Futures Model would fail to protect FCM customers against fellow customer risk (though to differing degrees) and would hamper portability. The Complete Legal Segregation Model also is operationally easier to implement than the Full Physical Segregation Model. However, MFA believes that the Commission should permit FCM customers who would prefer Full Physical Segregation to elect such increased protection as long as it can be accomplished within the Complete Legal Segregation Model."


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