On October 17th, the Division of Clearing and Risk issued an interpretation clarifying that while CFTC Regulation 22.2(d) prohibits a futures commission merchant from placing a lien on the cleared swaps customer collateral it holds, the regulation does not prohibit a cleared swaps customer from granting a lien on his or her own account at the FCM, nor does the regulation prohibit the FCM from taking action to foster the cleared swaps customer's grant of such a lien. CFTC Letter No. 12-28.