The protection of customers and the safeguarding of their funds is a fundamental component of the CFTC's regulatory framework. Confidence in the entire financial system was shaken in the 2008 meltdown, and confidence in the futures industry was severely damaged by the MF Global and PFG disasters. Something had to be done to assuage customer concern. These new rules are undoubtedly detailed and well intentioned and may well serve to prevent another FCM failure. These rules, however, are extremely complex and will be very costly to implement. For some FCMs this may be a burden that they can't or won't be able to bear. The Residual Interest rule in particular will stress the capital and liquidity of the smaller FCMs that service farmers and retail customers. These customers may be better informed in selecting an FCM, but the result may be fewer FCMs for these customers to choose from.
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