Among US financial regulators, the Joint Audit Committee speaks softly; but, for futures commission merchants that are clearing members of the Chicago Mercantile Exchange, it carries a big stick.  In this piece just published in the Futures and Derivatives Law Report, I examine the Joint Audit Committee's attempts to regulate the terms under which FCMs contract with their customers, by way of comparison with recent staff guidance from the Fed and the SEC.  

The Joint Audit Committee in the Post-Archegos Risk Management Regulatory Landscape Published by Futures and Derivatives Law Report