CFTC’s Division Of Clearing And Risk Issues Staff Interpretation Regarding Part 22

The staff of the Commodity Futures Trading Commission’s Division of Clearing and Risk today issued an interpretation regarding Part 22, under which Futures Commission Merchants and Derivatives Clearing Organizations must legally segregate each Cleared Swaps Customer’s collateral, but are permitted to operationally commingle the collateral of their Cleared Swaps Customers. The interpretation, in question and answer format, provides clarification regarding operational issues arising during preparation for the implementation of Part 22.