Dear Members – Many NIBA Members are already feeling the effects of CFTC Regulation 1.22 as FCMs begin to phase in the changes to margining customer accounts as enumerated. The so-called “residual interest” provision in the rule, due in November 2014, shortens the three-day period which customers currently have to meet margin requirements. The time period further shortens in four years. The NIBA has vigorously opposed CFTC Reg. 1.22 since it was proposed. Included as part of the sweeping customer protection rules enacted by the Commission as a result of the Dodd-Frank Act and in response to the failures of…