FIA submitted comments to the CFTC regarding the Residual Interest Deadline for FCMs, following a public roundtable on March 3, 2016.
The Residual Interest Deadline is the time by which an FCM must assure that it is holding in its customer segregated accounts residual interest that is at least equal to the amount by which its customers’ segregated accounts, in the aggregate, are undermargined.
FIA believes the 6:00 pm (Eastern) Residual Interest Deadline strikes the most appropriate balance between assuring the protection of customer funds and alleviating the significant financial and operational burdens that would be imposed on customers and FCMs alike if the Residual Interest Deadline were set at settlement or such other earlier time.
The full comment letter is available in Resources on the right.
