But it's unclear how the business models of most FCM's might be impacted.
Among the changes:
"Transactions between affiliates of a company where the two entities exchange money or funds also are restricted by the new CFTC rule. Firms would still be able to enter into agreements using customer funds with an external third party."
It all depends on what the CFTC decides on what the "effective date" of implementation is, it could be effective immediately once they get the votes needed or maybe at the start of the new yr, etc.
I am unclear what happens after the 180 days. For the previous rule (monitored by regulators we all thought) all customers were impacted as their cash money disappeared along with the CEO, the employees were impacted as they were fired, and more questions than answered have appeared. That was a pretty harsh punishment.
Who is to regulate the regulators? Fool me once, shame on you! Fool me twice, shame on me!