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ARTICLE · 22 JANUARY 2025

Financial Markets And Funds Quick Take | Issue 34

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In 2014, the Joint Audit Committee issued a Regulatory Alert insisting that futures commission merchant (FCM) clearing members treat separate accounts of the same beneficial owner as a single account for purposes.

United StatesFinance and Banking
Katten Muchin Rosenman LLP
Katten Muchin Rosenman LLP
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Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds.

The CFTC Codifies the Letter 19-17 Compliance Processes Around Separately Margined Accounts

By Stephen Morris

In 2014, the Joint Audit Committee issued a Regulatory Alert insisting that futures commission merchant (FCM) clearing members treat separate accounts of the same beneficial owner as a single account for purposes of US futures margin rules. In 2019, in response to the vigorous objections of FCMs to this interpretation, Commodity Futures Trading Commissiaon (CFTC) staff fashioned a matrix of compliance requirements (Letter 19-17) designed to permit FCM clearing members to treat separate accounts of the same beneficial owner as separate accounts for margin purposes, promising in doing so that these requirements would in due course be codified. Read about the margin adequacy rule.

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