Revised Adjusted Net Capital Requirements

SIFMA’s Capital Steering Committee provides comments to the Commodity Futures Trading Commission (CFTC) on the CFTC’s proposal regarding proposed changes to the net capital requirements for futures commission merchants (FCMs) and introducing brokers (B/Ds), RIN 3038-AC66.  SIFMA believes that the lack of any economic analysis offered for the CFTC proposal, and its inconsistency with the general thrust of, and a number of specific recommendations contained in, the Administration’s proposal as outlined in the U.S. Treasury’s recently released report (Treasury Report) argues against proceeding further with the proposal.