1. Introduction Regulation 1.25, promulgated by the United States Commodity Futures Trading Commission (“CFTC”), sets forth the types of products and instruments in which futures commission merchants (“FCMs”) and derivatives clearing organizations (“DCOs”) may invest customer funds held in segregated accounts (“Permissible Investments”).[1] Related regulations pertaining to “secured funds” (CFTC regulation 30.7), “cleared swap customer collateral funds–FCMs” (CFTC regulation 22.2), and “cleared swap customer collateral funds–DCOs” (CFTC regulation 22.3) require that investment of those categories of customer funds comply with CFTC regulation 1.25. Most recently, the CFTC amended the scope of Permissible Investments in accordance with the Dodd-Frank Wall Street…