CCC Receives Formal Request from Senator Stabenow for Recommendations

#PFGBest Customers

Are you a customer of PFGBest? The CCC is working with regulators and monitoring the court on behalf of PFG customers. At this stage, we are advising customers to gather their statements and prepare for a claims or account transfer process.

Stay tuned to our website for more information.

The CCC received a formal letter from Senator Stabenow (D-MI) requesting that we "evaluate current policies and any recommendations" we would like to make to the Committee "that would create stronger, safer markets and provide customers with greater protections".

Read Senator Stabenow Letter to the CCC

From the NY Times:

"She sent letters to consumer advocacy groups, including Americans for Financial Reform and the Commodity Customer Coalition, a group of MF Global clients hurt by the firm’s collapse. The committee also sought input from the Futures Industry Association, an influential trade group, and the CME Group, the for-profit exchange that polices brokerage firms."

Read the NY Times Article Here

#MFGlobal Customers

Are you a customer of MF Global? The CCC formally represents more than 200 clients in the bankruptcy process of MF Global on a pro bono basis, and informally represents thousands more in the public domain.

Get the latest news on #MFGlboal.

About John Roe 91 Articles
Co-Founder of the CCC and head of BTR Trading and Roe Capital Management.


  1. Next.

    Separate the regulatory arm of the CME, from its exchange-trading base. The conflicts of interests are so clear, that I wonder why Mr. Terry Duffy didn’t recognize the obvious conclusions. As a DSRO, the CME had a very specific regulatory obligation to its member firms and customers. As I’m sure Mr. Duffy is cognizant of, those member firms consist of FCM’s and customers, the men and women who facilitate the trades, that his firm serves as counterparties for.

    The MF Global Inc. bankruptcy has exposed that the size of the CME’s blind search for profit, has blinded itself of its regulatory responsibilities. The CME has lost its value, as a protector of client funds. Therefore, lets separate the regulatory arm of the CME, from the profit making arm. Clearly, its just a first step.

  2. Next.

    Increase the penalties for violating the sanctity of segregated funds. Civil fines and reprobation by the CFTC and the SEC, needs to be backed by a promise of penal retribution. The incentive to “claim ignorance”, by the top three corporate officers of MF Global Inc., would be greatly reduced, if collective ignorance, led to collective penal penalties. As in any malfeasance, let’s stop the incentive.

  3. Put in place the option for any customer of an FCM, to have their segregated funds, totally segregated. No commingling with other customers. No transfers to other affiliated entities. No pledging of excess segregated funds for all various and sundry “safe” investments. As long as the FED has ZIRP, I am not asking my FCM to invest MY funds, for their benefit. If any customer would prefer to invest their excess segregated funds with the FCM, and reap the investment benefits, so be it. All customers with segregated funds should reap some of the benefits of any FCM pledging or hypothecating that customer’s collateral. Give the customer the option to opt-out.

  4. Clarify bankruptcy code and/or SIPA,, so that next time they can’t go around the customer protections. This may involve special rules for a company with a complex structure, such as MFG. If the assets are in one corp and the customers in another, you can get stranded. This was not the intent of the bk law.

  5. Remove (and stop allowing) the following clauses from agreements with futures (and securities) brokers, because such clauses are creating a situation in the brokerage industry whereby the broker doesn’t hold what he told the customer to be holding.

    Example 1:
    Customer hereby grants to [insert FCM name here] the right to pledge, repledge, hypothecate, rehypothecate, or invest, either separately or with the property of other customers, any securities or other property held by [FCM name] for the accounts of Customer or as collateral therefore, including without limitation to any exchange or clearing house through which trades of Customer are executed.

    Example 2:
    We may pledge, repledge, hypothecate or rehypothecate, either separately or together with Securities of other customers, all Securities and Other Property that you, now or in the future, carry, hold or maintain in your account.

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