CFTC Allows Combined Margins at CME and FICC
Published Date: 4/20/2026
Rule
Summary
Starting April 15, 2026, certain broker-dealers who also clear futures at both the Chicago Mercantile Exchange and the Fixed Income Clearing Corporation can combine their customers’ margin funds into one account. This change helps these firms manage money more efficiently and could save customers and firms some cash by reducing extra margin requirements. It’s a smart move to make trading smoother and safer for everyone involved!
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Analyzed Economic Effects
5 provisions identified: 4 benefits, 1 costs, 0 mixed.
Cross-Margining Can Reduce Customer Margin
Starting April 15, 2026, customers of BD-FCM joint clearing members may elect to cross-margin U.S. Treasury securities cleared at FICC with related futures cleared at CME so margin models can net offsetting risks and reduce initial margin requirements; the petition includes an illustrative example where total initial margin fell from $343.24 million to $68.648 million (about an 80% reduction) under cross-margining.
Customers Must Sign Subordination Agreement
Customers choosing cross-margining must agree to have their FICC-cleared securities and related funds carried in a futures account and must enter a subordination agreement stating that their claim for XM Securities Customer Property will not receive customer treatment under the Exchange Act or SIPA and will not be treated as 'customer property' in a stock broker liquidation under chapter 7.
BD-FCMs May Hold Customer Funds at FICC
Starting April 15, 2026, joint clearing members that are dually-registered broker-dealers and futures commission merchants (``BD-FCMs'') may deposit customer funds and margin with FICC and hold securities positions and associated funds in a futures customer account at FICC, notwithstanding that FICC is not a permitted depository under CEA section 4d and Commission Regulations 1.20 and 1.49(d).
Bankruptcy Priority as Futures Customer Property
Under the Order, in a BD-FCM bankruptcy cross-margined customers' FICC-held positions and margin will be treated as customer property under Commission Part 190 and as net equity claims, giving them the same priority to distributions as other futures customers in the futures account class.
FICC Will Segregate XM Customer Margin in Specific Accounts
FICC will hold cross-margining customer margin either in a Federal Reserve Bank of New York account (co-located with certain other segregated customer margin if permitted by the Fed) or in a FDIC-insured commercial bank account; these FICC XM Customer Margin Accounts will be clearly labeled and separate from FICC's own assets and from BD-FCM proprietary margin accounts.
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