View or download a pdf of the letter here:

Americans for Financial Reform Education Fund and Consumer Federation of America, Food & Water Watch, Institute for Agriculture and Trade Policy, and Public Citizen sent a letter sharing their grave concerns with the justification and potentially calamitous precedent contained in the Commodity Futures Trading Commission’s (CFTC’s) proposed rulemaking for the Investment of Customer Funds by Futures Commission Merchants and Derivatives Clearing Organizations. This proposal would expand the list of permitted investments for customer funds to include foreign debt which could put customers at undue financial risk — avoiding such risk was the rationale for prohibiting these transactions in 2011 after the MF Global meltdown. In addition, the proposal also suggests that revenue and profits of the commodities exchanges and dealers would fulfill the statutory requirement that approved products meet a public interest standard. This distorted interpretation is contrary to the plain language of the statute and sets a potentially dangerous precedent for subsequent determinations of permitted investments of customer funds. Our comment urged the CFTC not to embed the profits of exchanges and brokers into the fabric of its definition of the public interest.