Since becoming effective on January 27, 2021, an amendment to US Commodity Futures Trading Commission (“CFTC”) Regulation 39.13(g)(8)(ii), passed in January 2020 (the “2020 Amendment”)1, has raised concerns among some market participants about futures commission merchants (“FCMs”) coming under commercial pressure to collect less initial margin, leading to heightened overall risk. At the core of… Continue reading CFTC Guidance Regarding Recent Amendment to Regulation 39.13(g)(8)(ii)