Staff of the Commodity Futures Trading Commission recommended that there be no change in the current time that futures commission merchants must put their own funds in their customer segregated accounts to cover for the aggregate undermargined amounts of their customers. Under CFTC rules, an FCM is prohibited from using the funds of one customer to satisfy the obligations of another customer. To help avoid this, the CFTC adopted a new rule in 2013 (click here to access CFTC Rule 1.22) that requires an FCM by 6 p.m. on each business day (T+1) to include in its customer segregated accounts an amount of its own capital at least equal to the amount of its customers aggregate margin deficits calculated as of the prior business day (T). Under the rule, as subsequently amended, the CFTC had to consider whether the time of FCMs’ top-up should be accelerated to the time of settlement on T+1 (i.e., before 6 p.m.) or some other time. Commission staff recommended not changing the current requirements following their consideration of comments received during a public roundtable earlier this year and in writing. In these comments, concern was expressed that if the CFTC accelerated the time of FCMs’ required top-up, it would increase costs to FCMs’ clients as FCMs would pass along the cost of utilizing the FCMs’ capital for this purpose. The CFTC will accept comments to the staff’s report through June 13, 2016.