This month marks the initiation of CFTC Regulation 1.22 implementation, often referred to as the “residual interest” rule. On November 14, the deadline for FCMs to post their own capital into customer segregated accounts which require additional margin moves to 6:00 pm ET on the settlement date. Obviously, this affects the deadline for your customers to increase their own funds. This past July and at our annual member meeting in September, NIBA presented several workshops explaining the requirements of this rule and its possible effects on your customer and FCM relationships. Please contact your FCM directly if you have questions,…