Posts Tagged ‘U.S. Futures Customer Segregated Funds’

CFTC FCM Financial Data Report – July, 2014

October 13, 2014

Ahead of next month’s FIA Expo in Chicago, I figured it would be a good time to take a fresh look at the CFTC’s monthly FCM Financial Data report. I admit that I haven’t looked at it for some time – the last time I posted anything here about it was back in February for the 2013 year-end report. (A link is here.)

So, refreshing: the CFTC data is published here: CFTC Link.

I saved the spreadsheet version of the CFTC report and then sort the FCM list by categories.

fcmdata July 2014 Sorted by Seg Required

fcmdata July 2014 Sorted by Secured Required

And new this time, I learned from this review that since my last peek, CFTC has started including Swaps Seg Funds required:

fcmdata July 2014 Sorted by Swaps Seg Required

So, a quick look at the numbers, compared to 2013 year-end:

Customer Seg Required totals:
July 2014: $148,214,002,848
December 2013: $143,741,158,888

A small increase of $5B.

The top 5 FCMs measured by Customer Seg were:
Goldman Sachs $18B
JP Morgan $17.3B
Deutsche Bank $$12.4B
Newedge $12.1B
Morgan Stanley $10.6B

Those five firms hold 47.65% of all the Customer Seg Funds.

The next 5 FCMs are:
Merrill Lynch $10B
Credit Suisse $8.8B
UBS Securities $7B
Barclays $6.2B
Citigroup $5.3B

Those top-10, all in, hold 73% of all the US Customer Seg Funds Required.
There were 63 firms that reported Customer Seg on their July 2014 FOCUS (or FCM 1-FR) reports. That’s down SIX FCMs from the December 2013 year-end reports.

Customer Secured Required totals:
Total Secured Funds (or 30.7) Required in July 2014 was $31,721,736,168.

The top 5 FCMs measured by Customer Secured were:

Goldman Sachs $7.2B
Barclays $3.4B
UBS Securities $3.3B
Newedge $3B
JP Morgan $2.9B

Those five firms hold 62.8% of all the Customer Secured Funds.

The next 5 FCMs are:
Credit Suisse $2.6B
Merrill Lynch $2.6B
Morgan Stanley $2.1B
Deutsche Bank $1B
Citigroup $931MM

Those top-10, all in, hold 92.6% of all the US Customer Seg Funds Required.
There were 53 firms that reported Customer Secured on their July 2014 FOCUS (or FCM 1-FR) reports.

Finally, the Customer Swaps Seg Required totals:
Total Swaps Seg Funds Required in July 2014 was $37,573,414,231.

Since there were only 22 FCMs/BDs/SDs that reported these funds, and since this is the first time I’ve looked at this, all the firms, their reported amounts, and the percent of the totals are listed below:

1. Credit Suisse $7,583,982,994 (20%)
2. Barclays $5,824,094,747 (15.5%)
3. Citigroup $5,475,668,782 (14.5%)
4. Morgan Stanley $4,633,503,266 (12.3%)
5. JP Morgan $4,010,710,065 (10.7%)
6. Goldman Sachs $2,353,995,394 (6.3%)
7. Merrill Lynch $2,065,002,087 (5.5%)
8. Wells Fargo $1,509,345,655 (4%)
9. Deutsche Bank $1,502,136,236 (4%)
10. UBS Securities $829,082,727 (2.2%)
11. HSBC $522,398,676 (1.4%)
12. Newedge $422,435,013 (1.1%)
13. BNP Paribas Securities $370,185,150 (1%)
14. State Street $315,334,914 (0.8%)
15. Mizuho $43,755,732 (0.1%)
16. Jefferies $41,203,000 (0.1%)
17. RBS $39,683,871 (0.1%)
18. Nomura $24,047,555 (0%)
19. Macquarrie $3,316,120 (0%)
20. ADM $2,687,874 (0%)
21. BNP Paribas Brokerage Services $731,813 (0%)
22. CHS Hedging $112,560 (0%)

2013 Year-End FCM Financial Data Report

February 16, 2014

Here are the 2013 results from the CFTC report on financial data for U.S. FCMs. The ORIGINAL source is here: CFTC Financial Data for FCMs

The same data sorted by U.S. Customer Seg required (FCM Data 2013 Year-End) is posted here. (Downloads as an Excel spreadsheet.)

For perspective, the same data (sorted by U.S. Customer Seg required) for year-end 2012 is posted here: (FCM Data 2012 Year-End) 2012 Year-End Results. (Also downloads as an Excel spreadsheet.)

The Details

The TOTAL US Customer Seg amount reported in 2013 was $143,741,158,888, compared to a 2012 amount of $145,900,203,492, down almost $2.15 billion. or roughly 1.5%.

Following is a list of all US FCMs that reported Customer Seg requirements in their December 2013 reports to CFTC.

1. Goldman Sachs – 1st in 2013, 1st in 2012, 2013 Seg required was $19,505,062,033 down about $600 MM.

2. JP Morgan Securities- 2nd in 2013, 2nd in 2012, 2013 Seg required was $16,068,072,825 down more than $2 B.

3. Newedge – 3rd in 2013, 3rd in 2012, 2013 Seg required was $13,164,428,650 down about $1.7 B.

4. Deutsche Bank – 4th in 2013, 4th in 2012, 2013 Seg required was $12,402,354,155 UP about $1.5 B.

5. Morgan Stanley – 5th in 2013, 7th in 2012, 2013 Seg required was $10,233,308,793 UP about $1.3 B.

6. Merrill Lynch – 6th in 2013, 8th in 2012, 2013 Seg required was $10,097,450,250 UP about $3 B.

7. UBS Securities – 7th in 2013, 5th in 2012, 2013 Seg required was $8,191,731,999 UP about $400 MM.

8. Credit Suisse – 8th in 2013, 9th in 2012, 2013 Seg required was $7,918,920,731 UP about $1.4 B.

9. Barclays Capital – 9th in 2013, 10th in 2012, 2013 Seg required was $6,377,915,171 UP about $170 MM.

10. Citigroup – 10th in 2013, 6th in 2012, 2013 Seg required was $4,844,742,715 down about $2.8 B.

11. RJ O’Brien – 11th in 2013, 11th in 2012, 2013 Seg required was $3,703,754,600 down about $100 MM.

12. ADM Investor Services – 12th in 2013, 12th in 2012, 2013 Seg required was $2,931,401,486 UP about $150 MM.

13. Mizuho Securities – 13th in 2013, 17th in 2012, 2013 Seg required was $2,054,124,905 UP about $300 MM.

14. BNP Paribas Prime Brokerage – 14th in 2013, 15th in 2012, 2013 Seg required was $2,019,918,460 UP bout $100 MM.

15. ABN AMRO Clearing Chicago – 15th in 2013, 13th in 2012, 2013 Seg required was $1,981,333,752 down about $500 MM.

16. Interactive Brokers – 16th in 2013, 16th in 2012, 2013 Seg required was $1,939,801,946 UP a little under $200 MM.

17. Jefferies Bache – 17th in 2013, 14th in 2012, 2013 Seg required was $1,879,889,000 down about $500 MM.

18. FC Stone – 18th in 2013, 19th in 2012, 2013 Seg required was $1,582,727,766 UP about $30 MM.

19. RBS Securities – 19th in 2013, 20th in 2012, 2013 Seg required was $1,449,331,490 down about $80 MM.

20. Rosenthal Collins Group – 20th in 2013, 18th in 2012, 2013 Seg required was $1,412,661,189 down about $17 MM.

21. MacQuarie Futures – 21st in 2013, 22nd in 2012, 2013 Seg required was $1,228,662,410 UP more than $230 MM.

22. HSBC Securities – 22nd in 2013, 21st in 2012, 2013 Seg required was $1,048,317,517 UP about $30 MM.

23. RBC Capital Markets – 23rd in 2013, 29th in 2012, 2013 Seg required was $913,109,618 UP about $350 MM.

24. BNP Paribas Securities – 24th in 2013, 31st in 2012, 2013 Seg required was $867,187,524 UP more than $300 MM.

25. Goldman Sachs Execution & Clearing – 25th in 2013, 24th in 2012, 2013 Seg required was $847,350,112 UP about $60 MM.

26. McVean Trading & Investments – 26th in 2013, 23rd in 2012, 2013 Seg required was $780,942,381 down about $140 MM.

27. Merrill Lynch Professional Clearing – 27th in 2013, 26th in 2012, 2013 Seg required was $768,875,721 UP about $160 MM.

28. Santander Investment – 28th in 2013, 30th in 2012, 2013 Seg required was $755,009,247 UP about $190 MM.

29. JP Morgan Clearing – 29th in 2013, 32nd in 2012, 2013 Seg required was $700,772,180 UP about $170 MM.

30. Timber Hill – 30th in 2013, 27th in 2012, 2013 Seg required was $697,230,646 UP about $85 MM.

31. Morgan Stanley Smith Barney – 31st in 2013, 25th in 2012, 2013 Seg required was $541,746,031 down about $110 MM.

32. Vision Fin’l Markets – 32nd in 2013, 28th in 2012, 2013 Seg required was $508,664,310 down a little more than $100 MM.

33. KCG Americas – 33rd in 2013, 34th in 2012, 2013 Seg required was $479,067,087 UP about $63 MM.

34. Advantage Futures – 34th in 2013, 33rd in 2012, 2013 Seg required was $472,691,258 down about $18 MM.

35. Tradestation – 35th in 2013, 35rd in 2012, 2013 Seg required was $405,195,906 UP about $17 MM.

36. State Street – 36th in 2013, 44th in 2012, 2013 Seg required was $313,855,544 UP more than $210 MM.

37. Rand Financial – 37th in 2013, 36th in 2012, 2013 Seg required was $305,541,900 down about $70 MM.

38. EFL Futures – 38th in 2013, NOT ON LIST in 2012, 2013 Seg required was $251,656,003 UP $251 MM.

39. ED&F Man Capital Mkts – 39th in 2013, 61st in 2012, 2013 Seg required was $224,076,887 UP around $200 MM.

40. Gain Capital – 40th in 2013, 43rd in 2012, 2013 Seg required was $141,613,581 UP around $28 MM.

41. Dorman Trading – 41st in 2013, 40th in 2012, 2013 Seg required was $139,473,664 UP around $5 MM.

42. CHS Hedging – 42nd in 2013, 39th in 2012, 2013 Seg required was $138,600,871 down around $62 MM.

43. Phillip Futures – 43rd in 2013, 38th in 2012, 2013 Seg required was $128,018,797 down around $90 MM.

44. UBS Financial Services – 44th in 2013, 42nd in 2012, 2013 Seg required was $127,693,950 UP around $11 MM.

45. BNY Mellon Clearing – 45th in 2013, 41st in 2012, 2013 Seg required was $127,163,740 UP a little over $2 MM.

46. TD Ameritrade – 46th in 2013, 45th in 2012, 2013 Seg required was $125,798,949 UP around $26 MM.

47. Straits Fin’l – 47th in 2013, 47th in 2012, 2013 Seg required was $105,553,578 UP around $21 MM.

48. Marex North America – 48th in 2013, 50th in 2012, 2013 Seg required was $103,751,249 UP around $26 MM.

49. Optionsxpress – 49th in 2013, 48th in 2012, 2013 Seg required was $88,080,380 UP around $2.5 MM.

50. Cunningham Commodities – 50th in 2013, 49th in 2012, 2013 Seg required was $78,442,862 down around $5 MM.

51. Linn Group – 51st in 2013, 51st in 2012, 2013 Seg required was $76,819,233 UP around $1.3 MM.

52. Crossland – 52nd in 2013, 46th in 2012, 2013 Seg required was $76,240,649 down around $8 MM.

53. Institutional Liquidity* – 53rd in 2013, NOT ON LIST in 2012, 2013 Seg required was $54,415,840 UP $54.4 MM.

54. York Business Associates – 54th in 2013, 53rd in 2012, 2013 Seg required was $50,049,543 down around $9.6 MM.

55. Nomura Securities – 55th in 2013, 59th in 2012, 2013 Seg required was $48,479,739 UP around $17 MM.

56. AMP Global Clearing – 56th in 2013, 56th in 2012, 2013 Seg required was $42,518,643 UP around $4.5 MM.

57. E Trade Clearing – 57th in 2013, NOT ON LIST in 2012, 2013 Seg required was $39,409,278 UP $39 MM.

58. Mid Co Commodities – 58th in 2013, 55th in 2012, 2013 Seg required was $36,944,999 down around $2 MM.

59. Ironbeam – 59th in 2013, 54th in 2012, 2013 Seg required was $36,264,716 down around $11.5 MM.

60. Xchange Financial Access – 60th in 2013, NOT ON LIST in 2012, 2013 Seg required was $27,685,254 UP $27.6 MM.

61. Frontier Futures – 61st in 2013, 60th in 2012, 2013 Seg required was $25,658,100 down a little less that $5 MM.

62. Wells Fargo Securities* – 62nd in 2013, NOT ON LIST in 2012, 2013 Seg required was $21,409,743 UP $21.4 MM.

63. Oppenheimer & Co. – 63rd in 2013, 58th in 2012, 2013 Seg required was $13,893,625 down around $19 MM.

64. GH Financials – 64th in 2013, 68th in 2012, 2013 Seg required was $6,012,801 UP about $5.5 MM.

65. Daiwa Capital Mkts America – 65th in 2013, 64th in 2012, 2013 Seg required was $4,340,614 UP about $1.3 MM.

66. Friedberg Mercantile Group – 66th in 2013, 62nd in 2012, 2013 Seg required was $3,996,235 down about $5 MM.

67. LEK Securities – 67th in 2013, 63rd in 2012, 2013 Seg required was $2,309,600 down about $2.5 MM.

68. Cantor Fitzgerald – 68th in 2013, 67th in 2012, 2013 Seg required was $1,312,018 UP about $100K.

69. Alpari (US) – 69th in 2013, 66th in 2012, 2013 Seg required was $322,439 down about $1.7 MM.

* – Institutional Liquidity and Wells Fargo Securities were both on the list as an FCM in 2012 but both FCMs had zero for Customer Seg Required.

CFTC FCM Data – September 2013

November 13, 2013

Interesting results from the latest available CFTC report on financial data for U.S. FCMs. Source is here: CFTC Financial Data for FCMs

The same data sorted by U.S. Customer Seg required is posted here. (Downloads as an Excel spreadsheet.)

The data shows that now, the first five FCMs have just barely 50% of the U.S. Customer Seg. In August that figure was just under 50%, so there is small growth at the top of the list in terms of percentages. But the total U.S. Seg balances are down more than $4 billion, month over month. There was $146,879,480,741 in Customer Seg in August, there was just $142,493,827,451 reported at the end of September.

Also interesting to note that the 3rd and 4th biggest FCMs as measured by U.S. Customer Seg have swapped places: in August, Newedge was third, Deutsche Bank was fourth, now DB is third and Newedge is fourth.

The top 5 in Customer Seg – Goldman, JP Morgan, DB, Newedge and Morgan Stanley are the same as they were in August. The next five in September were Merrill Lynch, UBS, Credit Suisse, Barclays and Citi. In August, UBS was slightly larger than Merrill.

69 FCMs processed U.S. Customer Seg in September. Four of them processed more than $10 billion. 21 FCMs processed more than $1 billion in Customer Segregated Funds.

For those interested in such things, here is the same data sorted by Part 30.7, or Secured, balances. (Also downloads as an Excel spreadsheet.)

Goldman was the largest FCM measured by Customer Seg. It is also the largest measured by 30.7 Secured. Looking at the 30.7 side, Goldman has twice as much 30.7 required at the second-place FCM, UBS. They also have twice as Customer Seg as UBS.

Interesting, Secured balances are even more concentrated at the top than Customer Seg is. Far more concentrated, in fact. 65% of the Secured balances are processed at just the top-5 FCMs. 93% of the Secured money is processed at the top-10 FCMs. 55 FCMs process Secured balances. Only eight of them have Secured balances of more than $1 billion.

Do you see anything interesting in all these figures? Drop a comment in below, if you do. 

U.S. FCM Violations: Customer Segregated and Secured, Minimum Capital Violations

September 27, 2013

UPDATE:Updating, 10/13/2014 with additional CFTC finding in 2014.

UPDATE: I am going to start adding Secured (30.7) violations and FCM minimum capital violations too. I also changed the blog post title. This post still does not include LIBOR violations, nor various precious metal scams, nor simple supervision violations.

Since, alas, it has become so hard to keep track of all the FCM violations of Customer Seg Funds regulations, I decided to create this so I have one place to refer to in the future. Note please that these are only Customer Seg violations, not violations of 30.7 regs nor of Retail Foreign Exchange Dealer (RFED) net capital requirements. Not various and sundry other ponzi schemes, fraudulent precious metal scams, or other violations. These are all just violations of the U.S. Customer Segregation rules and regulations. This post also doesn’t include the many and varied enforcement actions against all the bankers caught up in the LIBOR rip-off/scandal.

Source: Enforcement actions as archived on the CFTC website.

2014
October 8, 2014: Friedberg Mercantile Group (FMG): Firm was under-secured (30.7) in early February, 2013. Friedberg.

September 24, 2014: FXDirectDealer, LLC undercapitalized, under he CFTC’s FCM/Retail FX Dealer adjusted net capital rule requiring a minimum of $20MM. FXDirectDealer, LLC

May 19, 2014: Global Futures & Forex, Ltd., undercapitalized, under he CFTC’s FCM/Retail FX Dealer adjusted net capital rule requiring a minimum of $20MM. Global Futures & Forex, Ltd.

March 27, 2014: Morgan Stanley Smith Barney, under in Secured (30.7) funds and commingling customer and firm funds. MSSB.

2013
September 30, 2013: ADM Investor Services (ADMIS): Ugh. Add ADM to the list. Caught commingling customer and prop accounts in their Customer Seg account. ADMIS This appears to have ended in July 2011 and probably was self-reported.

September 27, 2013: Vision Financial: fined for Seg violations in 2008/09. Vision Financial

September 27, 2013: R.J. O’Brien: an inter-account transfer from Secured (30.7) to Seg, for a non-clearing FCM for whom RJO cleared, put the non-clearing FCM into a Secured deficit. RJO Ops apparently made the transfer to cover a Seg margin deficiency for the omnibus account but never told the non-clearing FCM, nor called the non-clearing FCM for additional funds. R.J. O’Brien

June 19, 2013: ABN Amro Chicago: fined for violations in 2011. ABN Amro

April 9, 2013: Interactive Brokers: the firm “failed to compute on a currency-by-currency basis the amount of customer funds on deposit and required to be on deposit in segregated accounts.” Interactive Brokers

February 19, 2013: Enskilda Futures Limited (EFL), a London-based Futures Commission Merchant (FCM) fined $125,000 for failure to maintain adequate capital after undermargining a proprietary omnibus account. Enskilda

January 3, 2013: Muzuho Securities fined for Secured 30.7 violations. Mizuho Securities

2012
December 3, 2012: MBF: Federal Court Orders MBF Clearing Corp. to Pay $650,000 for Violating Customer Fund Segregation Requirements. MBF judgement

November 21, 2012: Cantor Fitzgerald:operational inadequacies and under seg. Cantor Fitz

October 10, 2012: Farr Financial. (I had somehow missed this one last year. I’d also never heard of Farr Financial before now.) Improper investment of customer segregated funds. Farr Financial

July 10, 2012: Peregrine Financial: the infamous Russ Wasendorf theft of $215 million. Peregrine Financial and Russ Wasendorf.

April 4, 2012: JP Morgan: fined $20 million for using the customer seg funds of a FCM called LBI as “net free equity” covering intra-day credit that JP Morgan extended to LBI over a 22-month period. During the Lehman bankruptcy, when LBI requested JP Morgan to release the customer seg funds, JP Morgan refused because it was using the customer money to cover LBI proprietary credit lines. J. P. Morgan 2012

March 13, 2012: MBF: This is the original CFTC complaint against MBF, settled on December 3rd above. MBF original charges.

U.S. Futures Customers Pulled $10 Billion Out of the Futures Market

September 13, 2012

As many know, the CFTC publishes a list of U.S. futures commission merchants (FCMs) and the amount of customer money they have in their Segregated U.S. Funds bank balances. Today they published the list for month-end July, 2012, to their website.

The CFTC report comes from the FCM’s CFTC 1-FR reports, which are part of the SEC FOCUS report if the FCM is also a broker/dealer in U.S securities. If the FCM is not also a broker/dealer registered with the SEC, then they submit just the 1-FR to CFTC.

Here is the latest report from CFTC: Latest CFTC Report

Here is the same list, sorted by FCMs’ Customer Segregated Funds balances. fcmdata0712-sorted-by-Seg

There is a lot of interesting information and data in the report: RJ O’Brien is the largest FCM in the U.S. as measured by Customer Seg, that is not also an SEC-registered broker/dealer in U.S. securities, for example. Another example: 8 of the top 10 names on the list all use the same vendor back-office system. There are 69 FCMs that reported Customer Seg to SEC and/or CFTC. (There were 71 as-of last October, when MF Global turned on their money vaporizer; there were 70 until Peregrine went down.)

But that’s not the most interesting thing to me. To me, the most revealing thing about the current report is this: In June of 2011, 13 months ago, FCMs in the U.S. reported a cumulative $153,881,560,188.00 in Customer Segregated Funds. (I used the CFTC report from that date to generate this post, where the data was sorted: June 2011 Sorted Data.

Today’s report from CFTC shows a cumulative Customer Seg figure of $143,561,983,577.00.

That means that customers of U.S. FCMs have pulled $10,319,576,611 out of their FCMs in the past 13 months of CFTC reporting.

Even if one assumes that MF Global lost/stole/vaporized $1.6 billion and that Russ Wasendorf at Peregrine stole another $200 million, there is still a full $8 billion-plus that customers of FCMs took out, entirely on their own.

FCM customers have options: ETFs, mutual funds, stocks (with SIPC protection), etc. It looks like many are utilizing the options, and departing the futures industry.

A Tip of the Cap to CME Group

April 4, 2012

News broke today that CME Group would begin requiring clearing member firms to report every day their Customer Segregated Funds balances.

Details here, via John Lothian’s Newsletter.

This is great news, and is something that was advocated on this blog back in January.  The CME took it even further with the announcement that FCMs would be required to report twice-monthly on investments of Customer Seg Funds, which is a great idea too.

It isn’t everything I hoped it would be. There is no daily reportable file. Instead, reporting will be 1FR (FCM) and FOCUS (broker/dealer) based, and forms submitted or filled out on Windjammer. And there is no tracking of each customer account’s contribution to an FCMs Customer Seg balance.

But still, this is a great start.

Well done, CME. Well done indeed.

A Modest Proposal For A Better Way For Regulators To Track U.S. Futures Customer Segregated Funds

January 30, 2012

John Lothian has created a website where he is asking for users/registrants to add ideas for ways that the U.S. futures industry can recover from the collapse of future commission merchant (FCM) MF Global following the disclosure that hundreds of millions, possibly as much as $1.2 billion, of Customer Segregated Funds is “missing” from MF Global’s bank accounts. Lothian’s Futures Crowd Site

For the uninitiated: Customer Seg Funds are funds are cash balances and collateral deposited at FCMs, or funds earned from trading, that are, by rule and by law, required to be kept separate from firm money, and are intended to be held for the exclusive benefit of FCMs’ clients. I do not share the opinion that the Seg Funds “missing” from MF Global are missing due to any accounting error or “mistake.” I believe that the Seg Funds were taken by someone or some multiple people at the failed FCM to cover firm shortfalls. If and when this proves to be true, someone or some multiple people could well face prison, but that may be years from now.

In the meantime, John Lothian is asking for interested parties to offer ideas on how the U.S. futures industry can move forward after the apparent “disappearance” of millions of dollars of client funds. One of the ideas that was proposed was that missing client money should be restored immediately. That Suggestion Is Here. The original post was this:

“The number one priority: make customers whole…The number one priority to restore customer confidence should be to make the customers whole. Agree or disagree? No specific mechanism for making them whole is suggested here.

I concur with this idea and added the following comment:

I completely agree that the top priority is to make customers whole. I have had this argument with others and I do not buy into the “Slippery Slope” argument. I do not buy into the notion, though, that CME should make all the customers whole. Why not ICE, OCC, MGE, KCBOT too?

The American taxpayers got stuck bailing out so-called TBTF financial institutions. Know what really is Too Big To Fail? The U.S. Futures Industry, that’s what.

For one-six-hundreth of the cost of those bailouts, American taxpayers can restore integrity to the market, and make whole famers, retail investors, locals, and yes, even (GASP) speculators. . That needs to happen.

It won’t happen without industry-led regulatory changes, though. I have a proposal that is germinating in my mind about what that can and should look like. I will be adding that in the next day or two.

FCMs that are also broker-dealers must file a Financial and Operational Combined Uniform Single Report (FOCUS report) with the SEC every month. Part of the FOCUS report required for broker-dealers that are also FCMs is the Supplement Report called “Statement of Segregation Requirements and Funds in Segregation For Customers Trading on U.S. Commodity Exchanges.” I took a look at this report last November. For broker-dealers, the SEC passes along the Statement of Segregated Funds to the CFTC from each broker-dealers FOCUS report. The CFTC reports on this each month when it releases “FCM Data” and I’ve talked about those CFTC releases several times in the past: November, 2011 and June, 2011 and February, 2011 and January, 2011, for example.

FCMs that are not also broker-dealers must complete the exact same report – called the CFTC 1FR-FCM report – and submit it to the CFTC every month. The FCM 1-FR reports are incorporated into the CFTC FCM Data reports along with the FOCUS reports for broker-dealers.

As we see from the Statement of Segregation reports, whether from FOCUS (broker-dealer) or 1-FR (FCM), the FCMs track all required aspects of Customer Seg money on a regular basis. Each FCM must put this information together, at the very least, once per month. Some, it seems likely, do so daily as a normal part of their daily client processing. Those that do not calculate these figures daily certainly should. But none of them report the information, daily, in any meaningful way.

They should. Here’s how: today, every day, during an FCM’s night processing cycle, they calculate CFTC Large Trader position reports and create a print-image file (which gets archived in their data warehouse, whether it is Laser Vault, Speedscan, whatever). At the same time, the FCM creates an 80-byte Large Trader disk file which is delivered to the CFTC electronically, typically via FTP. The CFTC uses this information to track economic data and create economic reports.

I’d propose that FCM back-office systems be modified to do the same thing, for Customer Segregated Funds, on a daily basis. The systems already generate print-image reports that FCMs and broker-dealers use to complete their 1-FRs or FOCUS reports. These reports simply aggregate back-office system data at user-defined levels and create print-image reports (which are archived in data warehouses). The aggregation can be done monthly for regulatory reporting to SEC and/or CFTC – that’s already proven, FCMs do that regularly, so systems and functionality already exists for that. What does not exist today – what should be added – is creation of electronic files which can be delivered to regulators daily and used to track Customer Seg Funds, not just at the firm (FCM) level, but at the individual account level. (That’s what the back-office reports already do today, they generate detail reports at the customer level and also at the firm level. An FCM reports the firm-level, and archives the backing detail reports.)

The following fields need to be tracked, daily, for each FCM, for each customer account, and delivered electronically to CFTC, SEC, or some other outside entity that can use the data to track for anomalies, discrepancy, or other issues. If FCMs know that customer segregated funds are being tracked and analysed and reviewed daily, they’d be much more likely to preserve those funds when the FCM is in duress. And the data included in these new data files would likely make it much easier, in the event of an FCM failure, to move funds and positions to other FCMs in good standing, since they’d have ready access to the information.

1. Net Ledger Balance for each FCM client account.
1a. Cash
1b. Market Value of Securities

2. Net Unrelized P&L on futures positions (Open Trade Equity)

3. Option Value
3a. Add value of LONG options
3b. Subtract value of SHORT options

4. Net Equity: add lines 1, 2 and 3

5. Accounts liquidating to the negative Seg balance
5a. gross amount
5b. less market value of securities in those debit-balance accounts.

6. Amount to be Segregated (add lines 4 plus 5)

The figures above are the “client side” or the amounts in the bookkeeping system for clients. The figures below are the “house side” or the amounts that MUST be available. These figures might not be – and often are not – in the back-office bookkeeping system. Lines 1 though 5 should be generated for each client account, every day. Line 6 is the total amount of client funds that must be segregated. The lines below should also be tracked daily – and this might require changes to operational procedures at an FCM.

7. Amount deposited in Segregated Bank Accounts
7a. Cash
7b. Market value of securities posted by clients
7c. Market value of securities purchased with client money

8. Margin amount posted at regulated clearinghouses (DCOs)
9. Net Settlement (pay/collect) due to/from regulated clearinghouses (DCOs)

10. Option values cleared by FCM
10a. Add LONG option value
10b. Subtract SHORT option value

11. Amounts held at other FCMs for the clients of the FCM
11a. Net liquidating equity
11b. MArket value of securities purchased with customer funds
11c. FCM client securities pledged to the other FCM

12. Segregated funds in hand (petty cash)

13. Total (add lines 7 – 12)
14. Amount actually in Segregation (line 13 less line 6)

NOTE: I am closing the comment thread here (once I figure out how I figured out how) so the discussion can be encapsulated in one place. The place to discuss this topic is at John Lothian’s Futures Crowd website, in the Idea Thread for this topic. The link to that comment thread is here.