Futures Commission Merchant Regulation - Comment Letter - Managed Funds Association - August 8, 2011
|Final Rule Issue||Effective Date||Compliance Date|
|February 7, 2012||April 9, 2012||November 13, 2012|
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."