In 2012, NFA and CFTC introduced a range of rules aimed at increasing protection of customer funds held at FCMs. These rules, some of which are final and some of which are proposed but appear well on their way to implementation, generally enhance transparency, cement requirements for FCMs maintenance of FCM ‘residual interest’ amounts in customer segregated accounts, tighten up the types of investments FCMs may make with customer segregated assets, and require DCOs to compute FCM margin requirements without allowing the FCM to net the FCM’s different customers’ positions against each other. The rules heighten transparency by requiring FCMs…