The Securities Industry Association (SIA)* provide comments to the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on the treatment of security futures products and related customer funds, CFTC proposed Rule 41.42; SEC File No. S7-17-01.  The groups believe the proposals meet the statutory directive of avoiding conflicting or duplicative regulations affecting fully registered broker-dealer/futures commission merchants (FCMs), while generally leaving each entity the decision with respect to the manner in which the funds and positions are held.  The groups support the proposals, and offer their observations and recommendations.
*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.