The roundtable focused on (i) the role of an “Examination Expert” to review SRO examination programs, (ii) the proposed disclosures of firm specific risks and financial reporting, (iii) the proposed requirement for segregation and secured acknowledgement letters, and (iv) the proposed residual interest requirements for FCMs. (Click here to view my earlier blog on the proposed rulemaking, with analysis and commentary.)
The list of panelists is available here.
A video of the roundtable discussion will be made available on YouTube at http://www.youtube.com/user/CFTC or can be accessed through the CFTC’s website.
The comment period for the proposed rulemaking on Enhancing Protections Afforded Customers and Funds Deposited by Customers expires February 15, 2013.
Lofchie Comment: Among my (many) criticisms of Dodd-Frank is that the safety benefits which it was supposed to provide to customers have been greatly oversold. There is quite a good argument (as the failures of MF Global and Peregrine have made obvious) that swaps customers would be safer if their collateral were held by a custodial bank, as was possible in the pre-Dodd-Frank world, rather than by an FCM, as will be required by Dodd-Frank. In this regard, I note that “futurization” (the conversion of swaps into futures) means that customers will forego the custodial benefits of “LSOC” segregation of swaps collateral for the less restrictive segregation of futures collateral.