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ARTICLE · 22 JANUARY 2014

Corporate and Financial Weekly Digest - Volume IX, Issue 3

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The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight issued two no-action letters granting relief to futures commission merchants from certain requirements of the enhanced customer protection regulations that went into effect on January 13.

United StatesFinance and Banking
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Edited by Robert Weiss and Gregory Xethalis

CFTC

CFTC Issues No-Action Relief to FCMs Relating to Enhanced Customer Protection Rules

The Commodity Futures Trading Commission's Division of Swap Dealer and Intermediary Oversight (DSIO) issued two no-action letters granting relief to futures commission merchants (FCMs) from certain requirements of the enhanced customer protection regulations (Customer Protection Rules) that went into effect on January 13.

First, in Letter 14-02, DSIO provided time-limited no-action relief from the provisions of CFTC Regulations 1.20, 22.2 and 30.7 that prohibit the commingling of customer segregated funds, cleared swaps customer collateral and 30.7 funds. In the Federal Register release accompanying the Customer Protection Rules, the CFTC explained that these provisions would not prevent an FCM from accepting a single wire transfer to margin transactions in multiple account origins, provided (i) the funds were first

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