# CFTC Letter No. 25-38: Staff Interpretation Regarding FCM Deposits of Securities with Foreign Brokers and Foreign Clearing Organizations to Margin Customer Positions Entered into on, or Subject to the Rules of, a Foreign Board of Trade

> Federal · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/CFTC_L25_38

## Section

- **Citation:** CFTC Letter No. 25-38
- **Heading:** Staff Interpretation Regarding FCM Deposits of Securities with Foreign Brokers and Foreign Clearing Organizations to Margin Customer Positions Entered into on, or Subject to the Rules of, a Foreign Board of Trade
- **Jurisdiction:** Federal
- **Kind:** Agency guidance
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** CFTC Staff Letters (2008-present) / Staff Interpretation Regarding FCM Deposits of Securities with Foreign Brokers and Foreign Clearing Organizations to Margin Customer Positions Entered into on, or Subject to the Rules of, a Foreign Board of Trade.

## Text

Summary: Staff Interpretation Regarding FCM Deposits of Securities with Foreign Brokers and Foreign Clearing Organizations to Margin Customer Positions Entered into on, or Subject to the Rules of, a Foreign Board of Trade.

CFTC Letter No. 25-38 Interpretative November 25, 2025
1

U.S. COMMODITY FUTURES TRADING COMMISSION
Three Lafayette Centre, 1155 21st Street, NW, Washington, DC 20581
www.cftc.gov

Market Participants

Division
Thomas J. Smith
Acting Director

RE: Staff Interpretation Regarding FCM Deposits of Securities with Foreign Brokers and
Foreign Clearing Organizations to Margin Customer Positions Entered into on, or
Subject to the Rules of, a Foreign Board of Trade
The Market Participants Division (“MPD” or “Division”) of the Commodity Futures Trading
Commission (“CFTC” or “Commission”) is issuing this letter in response to a request from the
Futures Industry Association (“FIA”) on behalf of its members that are futures commission
merchants (“FCMs”) and similarly situated FCMs.1 FIA requests that MPD issue an interpretative
letter pursuant to Commission Regulation 140.992 confirming that an FCM may post customer-
owned securities and securities purchased with customer funds (collectively, “Customer
Securities”) with foreign brokers and foreign clearing organizations (together, “foreign
intermediaries”) to margin customers’ foreign futures and foreign options positions3 under
circumstances where the foreign broker or foreign clearing organization is authorized or required

1 FIA is a global trade organization for futures, options, and centrally cleared derivatives markets. FIA’s core
constituency consists of firms that operate as clearing members in global derivatives markets, including firms
registered with the Commission as FCMs
foreign options positions3 under
circumstances where the foreign broker or foreign clearing organization is authorized or required

1 FIA is a global trade organization for futures, options, and centrally cleared derivatives markets. FIA’s core
constituency consists of firms that operate as clearing members in global derivatives markets, including firms
registered with the Commission as FCMs.
2 17 CFR 140.99. Commission regulations referred to in this interpretation may be found at 17 CFR Chapter I and
are available through the Commission’s website, www.cftc.gov.
3 The terms “foreign futures” and “foreign options” are defined in Commission Regulation 30.1 to generally mean
any futures or option positions made, or to be made, on or subject to the rules of any foreign board of trade. 17 CFR
30.1.

CFTC Letter No. 25-38 Interpretative November 25, 2025
2

by local law to obtain title to, or a right of re-use over,4 the Customer Securities (the “Request for
Interpretation”).
I.
Regulatory Background
Section 4(b) of the Commodity Exchange Act (“CEA”)5 grants the Commission authority to
regulate an FCM’s foreign futures and foreign options activity.6 The Commission has
implemented this statutory authority through its Part 30 regulations.7
As part of this regulatory authority, Commission Regulation 30.7 sets forth requirements regarding
an FCM’s treatment and holding of funds deposited by customers as margin for foreign futures
and foreign options transactions and positions (“30.7 Customers”).8 The requirements include an
obligation for an FCM to maintain at all times a sufficient amount of funds in specially designated
accounts to satisfy the total account balances of all 30.7 Customers (“30.7 Customer Funds”).9
The 30.7 Customer Funds also must be held by depositories specified by the regulations
(“Permitted Depositories”) and titled under account names that clearly identify the funds as
belonging to 30.7 Customers.10 Commission Regulation 30.7 further requires an FCM to obtain
ds in specially designated
accounts to satisfy the total account balances of all 30.7 Customers (“30.7 Customer Funds”).9
The 30.7 Customer Funds also must be held by depositories specified by the regulations
(“Permitted Depositories”) and titled under account names that clearly identify the funds as
belonging to 30.7 Customers.10 Commission Regulation 30.7 further requires an FCM to obtain
from each Permitted Depository an acknowledgment letter that includes a provision specifying
that the 30.7 Customer Funds must be treated by the depository in accordance with Section 4(b)
of the Act and Commission Regulation 30.7.11
Commission Regulation 30.7 also limits the amount of 30.7 Customer Funds that an FCM may
deposit with certain Permitted Depositories located outside of the U.S. Pursuant to Commission

4 The term “right of use” or “right to re-use” in this interpretation refers to a customer granting a legal right to use
Customer Securities transferred to a foreign intermediary as margin collateral, but only under specific conditions
outlined in an agreement between the parties.
5 7 U.S.C. 1 et. seq. The CEA may also be accessed through the Commission’s website, www.cftc.gov.
6 7 U.S.C. 6(b). CEA Section 4(b)(2)(A) (7 U.S.C. 6(b)(2)(A)) states, in relevant part, that the Commission may
adopt regulations requiring the safeguarding of customer funds by any person located in the U.S. who engages in the
offer or sale of futures contracts or options on futures contracts that are made on, or subject to the rules of, a board
of trade, exchange, or market located outside of the U.S.
7 17 CFR Part 30.
8 17 CFR 30.7. Commission Regulation 30.1 defines the term “30.7 customer” to include both U.S. and non-U.S.
persons who trade foreign futures or foreign options through an FCM. 17 CFR 30.1.
9 17 CFR 30.7(a)
of futures contracts or options on futures contracts that are made on, or subject to the rules of, a board
of trade, exchange, or market located outside of the U.S.
7 17 CFR Part 30.
8 17 CFR 30.7. Commission Regulation 30.1 defines the term “30.7 customer” to include both U.S. and non-U.S.
persons who trade foreign futures or foreign options through an FCM. 17 CFR 30.1.
9 17 CFR 30.7(a). Commission Regulation 30.1 defines the term “30.7 customer funds” to mean any money,
securities, or other property received by an FCM from, for, or on behalf of 30.7 Customers to margin, guarantee, or
secure foreign futures or foreign option positions. 17 CFR 30.1.
10 17 CFR 30.7(b). Permitted depositories are limited to banks or trust companies located in the U.S.; banks or trust
companies located in non-U.S. jurisdictions that have in excess of $1 billion of regulatory capital; FCMs registered
with the Commission; Commission designated clearing organizations; clearing organizations of foreign boards of
trade; members of foreign boards of trade; or designated depositories of members of foreign boards of trade or
foreign clearing organizations.
11 17 CFR 30.7(d) and Appendix E to Part 30.

CFTC Letter No. 25-38 Interpretative November 25, 2025
3

Regulation 30.7(c), an FCM may deposit with a foreign broker a maximum of 120 percent of the
total amount of margin required by the foreign broker for the foreign futures and foreign options
positions of 30.7 Customers.12
The restrictions that are most relevant to FIA’s Request for Interpretation, however, are: (i) that an
FCM must deposit 30.7 Customer Funds under the laws and regulations of the foreign jurisdiction
that provide the greatest degree of protection to such funds, and (ii) that an FCM may not waive
any of the protections afforded 30.7 Customer Funds under the laws of the foreign jurisdiction
(collectively, the “Customer Funds Restrictions”).13 The Commission adopted the Customer
Funds Restrictions in 2013 as part of the overall enhancem
er the laws and regulations of the foreign jurisdiction
that provide the greatest degree of protection to such funds, and (ii) that an FCM may not waive
any of the protections afforded 30.7 Customer Funds under the laws of the foreign jurisdiction
(collectively, the “Customer Funds Restrictions”).13 The Commission adopted the Customer
Funds Restrictions in 2013 as part of the overall enhancement of the protections afforded to
customers, including the holding of their funds.14 The Customer Funds Restrictions were also
adopted in response to a dispute in an FCM bankruptcy proceeding concerning the legal status of
Customer Securities that were deposited by the FCM with its foreign broker affiliate as margin for
30.7 Customers’ foreign futures and foreign options positions. The Trustee for the FCM in the
bankruptcy proceeding asserted that the Customer Securities should be returned by the foreign
affiliate to the 30.7 Customers as protected client assets under relevant foreign law. The
administrator for the foreign affiliate that was in an insolvency proceeding under local law,
however, appeared to claim that the FCM opted out of the standard client asset protection regime
and elected an alternative legal structure under local law. The alternative regime, if elected, would
involve an absolute title transfer of the Customer Securities to the foreign affiliate and would have
further resulted in the FCM and 30.7 Customers effectively becoming general creditors in the event
of the insolvency of the foreign affiliate.15 The Customer Funds Restrictions are intended to ensure
that an FCM maintains 30.7 Customer Funds with foreign intermediaries consistent with
applicable customer asset protections offered in the foreign jurisdictions and does not elect
alternative regimes that provide less protection to 30.7 Customer Funds in the event of the
insolvency of a foreign intermediary
ncy of the foreign affiliate.15 The Customer Funds Restrictions are intended to ensure
that an FCM maintains 30.7 Customer Funds with foreign intermediaries consistent with
applicable customer asset protections offered in the foreign jurisdictions and does not elect
alternative regimes that provide less protection to 30.7 Customer Funds in the event of the
insolvency of a foreign intermediary.
Commission staff also issued two no-action letters for an FCM depositing Customer Securities
with a foreign broker affiliate under a right of re-use.16 In discussing the facts presented in the

12 17 CFR 30.7(c). Commission Regulation 30.7(c) limits the amount of 30.7 customer funds that may be deposited
with any non-U.S. depository to the amount of margin required for the 30.7 customers’ foreign futures and foreign
option positions, plus an additional 20 percent of the required margin to minimize the frequency of transfers
between U.S. and non-U.S. depositories. MPD staff, however, issued a no-action position for FCM deposits of 30.7
Customer Funds with non-U.S. banks and non-U.S. clearing organizations that otherwise meet the qualifications as a
Permitted Depository from the restriction. CFTC Staff Letter No. 14-138 (Nov. 13, 2014), available at:
https://www.cftc.gov/sites/default/files/idc/groups/public/@lrlettergeneral/documents/letter/14-138.pdf.
13 17 CFR 30.7(c).
14 Enhancing Protections Afforded Customers and Customer Funds Held by Futures Commission Merchants and
Derivatives Clearing Organizations, 78 FR 68506 (Nov. 14, 2013).
15 Report of the Trustee’s Investigation and Recommendations, In re MF Global, Inc., Debtor, Case No. 11-2790
(MG) (SIPA), (Bankr. S.D.N.Y). The legal dispute was ultimately settled by the parties.
16 CFTC Staff Letter No. 16-88 (Dec. 19, 2016), available at: https://www.cftc.gov/csl/16-88/download, as modified
by CFTC Staff Letter No. 18-26 (Oct. 31, 2018), available at: https://www.cftc.gov/csl/18-26/download. Letter 16-
stigation and Recommendations, In re MF Global, Inc., Debtor, Case No. 11-2790
(MG) (SIPA), (Bankr. S.D.N.Y). The legal dispute was ultimately settled by the parties.
16 CFTC Staff Letter No. 16-88 (Dec. 19, 2016), available at: https://www.cftc.gov/csl/16-88/download, as modified
by CFTC Staff Letter No. 18-26 (Oct. 31, 2018), available at: https://www.cftc.gov/csl/18-26/download. Letter 16-

CFTC Letter No. 25-38 Interpretative November 25, 2025
4

request for a no-action position, staff stated that Commission regulations prohibit an FCM from
transferring Customer Securities by title transfer. Staff Letters 16-88 and 18-26, however, were in
response to specific facts and circumstances applicable to the regulatory requirements of the
United Kingdom, including the applicable title transfer and right of re-use requirements, and were
not intended to represent the Division’s views with respect to all circumstances involving title
transfer, including situations where title transfer or right of re-use is authorized or required under
the applicable local regulatory regime and/or rules of the foreign board of trade or foreign clearing
organization.
II.
Summary of the Request for Interpretation
FIA’s Request for Interpretation seeks clarification and confirmation that an FCM would not be in
violation of its obligations under Commission Regulation 30.7 and the Customer Funds
Restrictions, and a foreign broker or foreign clearing organization that is a Permitted Depository
under Commission Regulation 30.7(b) would not be in violation of its obligations under the
acknowledgment letter required by Commission Regulation 30.7(d), if the foreign broker or a
foreign clearing organization were to take title to, or invoke a right of re-use over, Customer
Securities that the FCM deposits to margin the foreign future and foreign option positions of 30.7
Customers
ository
under Commission Regulation 30.7(b) would not be in violation of its obligations under the
acknowledgment letter required by Commission Regulation 30.7(d), if the foreign broker or a
foreign clearing organization were to take title to, or invoke a right of re-use over, Customer
Securities that the FCM deposits to margin the foreign future and foreign option positions of 30.7
Customers. The Request for Interpretation specifies that any title transfer or right of re-use must
be authorized or required under the applicable local regulatory regime or rules of the foreign board
of trade or foreign clearing organization, and that the Customer Securities may be used or re-used
by the foreign broker or foreign clearing organization solely for the purpose of margining or
securing 30.7 Customer obligations arising from 30.7 Customers’ foreign futures and foreign
option positions.
In support of its Request for Interpretation, FIA asserts that FCMs are currently operating in
foreign futures markets at a significant disadvantage to their foreign competitors, including
competitors located, or participating on markets located, in the European Union and United
Kingdom. FIA states that firms operating in non-U.S. jurisdictions are not constrained in their
ability under applicable foreign law to post securities belonging to customers with other foreign
brokers or foreign clearing organizations as margin for customer positions. In addition, FIA notes
that certain jurisdictions in Europe and Asia affirmatively require clearing members of a foreign
board of trade to transfer title of customer securities deposited as margin funds to foreign clearing
organizations.
FIA also represents that the competitive disadvantage is heightened by the fact that most
institutional customers of FCMs prefer to meet margin requirements for foreign futures and foreign
options positions with securities, consisting primarily of U.S. Treasury securities and other highly
liquid foreign sovereign debt securities
ies deposited as margin funds to foreign clearing
organizations.
FIA also represents that the competitive disadvantage is heightened by the fact that most
institutional customers of FCMs prefer to meet margin requirements for foreign futures and foreign
options positions with securities, consisting primarily of U.S. Treasury securities and other highly
liquid foreign sovereign debt securities. FIA notes that as of July 2025, FCMs collectively held

88 and Letter 18-26 were issued by staff in MPD’s predecessor division, the Division of Swap Dealer and
Intermediary Oversight.

CFTC Letter No. 25-38 Interpretative November 25, 2025
5

$55.2 billion of 30.7 Customer Funds for trading foreign futures and foreign options, with
approximately $22.7 billion comprised of Customer Securities.17
FIA further argues that due to the uncertainty stemming from Staff Letters 16-88 and 18-26, many
FCMs feel compelled to either limit their 30.7 Customers’ ability to deposit Customer Securities
as margin for foreign futures and foreign option positions or to source cash from the FCMs’
residual interest in the 30.7 Customer accounts to meet margin obligations to foreign brokers or
foreign clearing organizations. Alternatively, FIA states that FCMs must require their 30.7
Customers to post cash as margin, limit their 30.7 Customers’ activity on foreign markets, or accept
Customer Securities as margin without being able to pass the securities on to foreign brokers or
foreign clearing organizations that operate in title transfer regimes. FIA asserts that none of these
options are desirable or serve the interest of the FCMs or their 30.7 Customers as the options raise
significant funding challenges to FCMs and may result in increased costs or reduced access to
foreign markets and clearing for 30.7 Customers.
FIA also states that its Request for Interpretation is consistent with longstanding Commission
guidance
ansfer regimes. FIA asserts that none of these
options are desirable or serve the interest of the FCMs or their 30.7 Customers as the options raise
significant funding challenges to FCMs and may result in increased costs or reduced access to
foreign markets and clearing for 30.7 Customers.
FIA also states that its Request for Interpretation is consistent with longstanding Commission
guidance. FIA notes that in October 2000, the Commission revised an interpretation regarding the
holding of 30.7 Customer funds contained in Appendix B to Part 30.18 Prior to the October 2000
revision of Appendix B, the Commission interpreted Commission Regulation 30.7 to require each
FCM to deposit proprietary funds in a designated 30.7 Customer segregated account (i.e., set aside
proprietary funds in a “Mirror Account”) in the event that the FCM became aware of facts leading
it to conclude that 30.7 Customer Funds were not being handled by the initial depository (e.g., a
foreign broker), or any subsequent depository, in a manner consistent with the requirements of
Commission Regulation 30.7.19
The October 2000 revisions to Appendix B eliminated the Mirror Account requirement provided
that the FCM obtains the acknowledgment letter specified in Commission Regulation 30.7(d) from
the initial Permitted Depository and provides the 30.7 Customers with specific disclosures
regarding the risks of trading on foreign markets. The specific disclosure that an FCM is required
to provide include statements informing 30.7 Customers that: (i) the CFTC does not regulate the

17 Request for Interpretation at fn. 4 (referring to Selected FCM Financial Data as of July 31, 2025 available here).
Customer-owned securities and securities purchased with 30.7 Customer Funds represented approximately $14.7
billion and $6 billion, respectively, of the $22.7 billion in securities held by FCMs in July 2025.
FCMs are permitted by Commission Regulation 30.7(h) to invest 30.7 Customer funds in U.S
erpretation at fn. 4 (referring to Selected FCM Financial Data as of July 31, 2025 available here).
Customer-owned securities and securities purchased with 30.7 Customer Funds represented approximately $14.7
billion and $6 billion, respectively, of the $22.7 billion in securities held by FCMs in July 2025.
FCMs are permitted by Commission Regulation 30.7(h) to invest 30.7 Customer funds in U.S. Treasury securities
and obligations fully guaranteed as to principal and interest by the U.S.; municipal securities; U.S. agency
obligations; U.S. Government money market funds; exchange-traded funds comprised of short-term U.S. Treasury
securities; and general sovereign debt obligations of Canada, France, Germany, Japan, and the U.K. 17 CFR
30.7(h).
18 Foreign Futures and Foreign Options Transactions, 65 FR 60558, 60559 (Oct. 11, 2000), codified as Appendix B
to Commission Rule 30.7 (“Appendix B”).
19 The Mirror Account helped ensure that an FCM would meet its obligations to 30.7 Customers in the event of the
insolvency of the FCM and the failure of the depository to return the 30.7 Customer Funds.

CFTC Letter No. 25-38 Interpretative November 25, 2025
6

activities of foreign exchanges, including the execution and clearing of transactions; (ii)
transactions on foreign markets may be subject to foreign regulations which offer different or
diminished investor protections than Commission regulations and thus may expose the 30.7
Customers to additional risk; and (iii) 30.7 Customer Funds may not be provided the same
protections as funds deposited to margin positions on CFTC-regulated markets.20 The disclosures
further provide that 30.7 Customers should familiarize themselves with the foreign rules that will
apply to their transactions before trading on foreign markets.21
FIA asserts that, provided that a foreign regime has adopted rules protecting the value of securities
over which title has been transferred in the event of an insolvency, it believes that an FCM may
deposit Customer Securi
closures
further provide that 30.7 Customers should familiarize themselves with the foreign rules that will
apply to their transactions before trading on foreign markets.21
FIA asserts that, provided that a foreign regime has adopted rules protecting the value of securities
over which title has been transferred in the event of an insolvency, it believes that an FCM may
deposit Customer Securities with foreign brokers and foreign clearing organizations operating
under such rules, consistent with the requirements of Commission Regulation 30.7 and Appendix
B to Part 30. FIA states that the requested relief would allow FCMs to more readily compete on
foreign markets and would bring meaningful savings to FCMs and 30.7 Customers, as FCMs
would be able to accept and use Customer Securities to margin positions of 30.7 Customers
without having to finance offshore margin deposits with proprietary cash.
III.
MPD Staff Interpretation
Based on the facts presented in the Request for Interpretation, the Division confirms that:
(1)
An FCM is not in violation of Commission Regulation 30.7 if it transfers Customer
Securities to a foreign broker, foreign board of trade, or foreign clearing organization under
a title transfer or right of re-use, provided that such title transfer or right of re-use is
authorized or required under the applicable local regulatory regime and/or rules of the
foreign board of trade or foreign clearing organization and the Customer Securities are
being transferred solely for purposes of margining or securing 30.7 Customer obligations
arising from 30.7 Customers’ foreign futures and foreign options positions; and
ded that such title transfer or right of re-use is
authorized or required under the applicable local regulatory regime and/or rules of the
foreign board of trade or foreign clearing organization and the Customer Securities are
being transferred solely for purposes of margining or securing 30.7 Customer obligations
arising from 30.7 Customers’ foreign futures and foreign options positions; and

(2)
A foreign broker or foreign clearing organization would not be in violation of its obligation
under the acknowledgment letter set forth in Appendix E to Part 30 if the foreign broker, a
foreign board of trade, or the foreign clearing organization takes title to, or invokes a right
of re-use over, Customer Securities deposited by an FCM, provided that title transfer or
right of re-use is authorized or required under the applicable local regulatory regime and/or
rules of the foreign board of trade or foreign clearing organization and the Customer
Securities are being transferred solely for purposes of margining or securing 30.7 Customer
obligations arising from 30.7 Customers’ foreign futures and foreign options positions.

20 17 CFR 1.55.
21 Id.

CFTC Letter No. 25-38 Interpretative November 25, 2025
7

The Division is issuing this interpretation in recognition that the Part 30 regulations were
developed under Section 4b of the CEA to provide a framework for FCMs to provide their
customers with access to foreign future and options markets. As discussed above, the Part 30
framework is designed to both protect 30.7 Customers and to inform 30.7 Customers of potential
differences in regulatory requirements that may present risks to 30.7 Customers. The Division,
however, recognizes that foreign brokers, exchanges, and clearing organizations operate under
laws and regulations that may differ from the Commission’s, including the laws and regulations
regarding the holding of customer funds
o both protect 30.7 Customers and to inform 30.7 Customers of potential
differences in regulatory requirements that may present risks to 30.7 Customers. The Division,
however, recognizes that foreign brokers, exchanges, and clearing organizations operate under
laws and regulations that may differ from the Commission’s, including the laws and regulations
regarding the holding of customer funds. The Customer Funds Restrictions discussed above are
intended to ensure that 30.7 Customer Funds are held in accordance with the applicable laws and
regulations governing the holding of customer funds deposited for trading futures and options on
futures in the relevant foreign jurisdictions and are used by the FCM and foreign intermediaries
solely to margin 30.7 Customers’ foreign futures and foreign options positions.

This interpretation also addresses any legal uncertainty arising from Staff Letters 16-88 and 18-
26. Confirmation from the Division that the title transfer of Customer Securities is not subject to
an outright prohibition under Commission Regulation 30.7 will remove the competitive
disadvantages that FCMs experience with respect to customers trading on foreign markets that are
discussed above. This confirmation and interpretation also have the potential to make foreign
futures markets more readily available to 30.7 Customers and reduce costs to 30.7 Customers and
FCMs.
This interpretation represents the position of the Division and does not necessarily represent the
views of the Commission or those of any other division or office of the Commission. This letter
and the interpretation set forth herein are based upon the facts and circumstances represented to
the staff of the Division. Any different, changed, or omitted material facts or circumstances may
require a different position or render this letter void
ivision and does not necessarily represent the
views of the Commission or those of any other division or office of the Commission. This letter
and the interpretation set forth herein are based upon the facts and circumstances represented to
the staff of the Division. Any different, changed, or omitted material facts or circumstances may
require a different position or render this letter void. As with all interpretative letters, the Division
retains the authority to condition further, modify, suspend, terminate, or otherwise restrict the
interpretation provided herein, in its discretion.
Sincerely,

___________________________________
Thomas J. Smith
Acting Director
Market Participants Division

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/CFTC_L25_38. Check the current official text before relying on it. Not legal advice.