On September 14th, the CFTC's Division of Clearing and Risk issued a letter interpreting Regulation 39.13(g)(8)(ii) (customer margin rule) to clarify that registered derivatives clearing organizations, in establishing customer initial margin requirements, may preserve historical practices by which customer initial margin requirements are based. Such requirements may be based on the type of customer account and reflect the application of prudential standards that result in futures commission merchants ("FCMs") collecting customer initial margin at levels commensurate with the risk presented by each type of customer account. CFTC Letter No. 12-08.