LSOC and Cleared Swaps Customer Protection

As part of the Dodd-Frank Wall Street Reform Act, the CFTC published new regulations that provide for additional cleared swaps customer protection. Part 22 of the CFTC’s regulations sets forth swaps customer protection standards, which are commonly referred to as “Legal Segregation with Operational Commingling”, or LSOC.

CME Clearing launched its LSOC rules and operational requirements on Wednesday, November 14, 2012. LSOC now applies to positions and collateral for customer cleared swaps. It does not apply to futures unless futures clear in the customer cleared swaps origin pursuant to DCO (Derivatives Clearing Organizations) rules for portfolio margining of futures versus swaps.

LSOC provides a fundamental change in how FCMs (Futures Commission Merchants) and DCOs treat cleared swaps customer positions and related collateral. The primary goals of LSOC are to:

  • Reduce fellow customer risk.
  • Protect cleared swaps customer collateral in the event that an FCM defaults to a DCO due to cleared swaps customer non-performance.

CME Clearing, in addition to adhering to LSOC regulations, seeks to offer cleared swaps customers some added enhancements that will provide more transparency, more control and ultimately better protection.

For additional information on LSOC, please contact CME Clearing at

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