FIA has submitted a response to the CFTC’s proposed rule requiring an operational resilience framework for futures commission merchants.
FIA notes that where the proposal is prescriptive, there is a risk that it may apply uniformly to all FCMs and be agnostic to their differences, which presents unnecessary challenges for the FCM community. In particular, the proposed rule may place a disproportionate burden on small or regional FCMs or FCMs that do not hold customer funds and may have more limited resources and divergent risk profiles. These FCMs are currently subject to different requirements under existing CFTC regulations.
FIA offers the CFTC several recommendations and items for consideration.
Read the response in full.
