Comparing CFTC Staff Letters 26-26 and 26-30 reveals two distinct types of conditional relief: a six-country securities-custody route for Eurex swaps and a wider but settlement-specific trust-company position for derivatives clearing houses.
A reconstruction of the CFTC’s August and September snapshots shows a $309m increase in funds above customer requirements. Firm-level movements demonstrate why that is not equivalent to $309m of new deposits.
An FXBrokers.ai reconstruction of CFTC returns finds $673.4 billion of reported customer property in August 2026. Domestic futures, foreign futures and cleared swaps all expanded, while the aggregate disclosed cushion remained broadly stable as a share of assets.