LSOC Implementation and Clearing Mandate

Published on:
June 4, 2013

The Asset Management Group of SIFMA (SIFMA AMG), the Investment Company Institute (ICI), and the Investment Adviser Association (IAA) provide comments to the Commodity Futures Trading Commission (CFTC) expressing concern with respect to the incomplete implementation of the protections provided to customer excess margin held by futures commission merchants (FCMs) and derivatives clearing organizations (DCOs) under the “legal segregation with operational commingling” (LSOC) model adopted by the CFTC.  

To ensure that customers benefit from the full margin protections offered by the LSOC model, the groups request that the CFTC Division of Clearing and Risk delay the deadline for mandatory clearing by Category 2 entities until September 9, 2013 (the deadline for Category 3 entities) to allow DCOs and FCMs the necessary time to implement the technological systems to provide these critical protections.

Details

Download

More Content

  • Letters
    Oct 22, 2026

    Treasury/IRS Notice 2026-49: Guidance on Section 324 of the SECURE 2.0 Act with Respect to Rollovers

    SIFMA supports modernizing retirement plan rollovers through standardized electronic processes, fraud safeguards and appropriate implementation timelines.
  • Amicus Briefs
    Oct 21, 2026

    In re USD LIBOR Litigation

  • Letters
    Oct 20, 2026

    SEC’s Proposed Rule Regulation Crypto Assets

    SIFMA and SIFMA AMG provide recommendations to the SEC on its proposed crypto asset regulation, addressing regulatory clarity, implementation and investor protection.

Get the latest trends, stats, and research on financial markets and securities.