PTG Responds to CFTC/SEC Joint Request for Comment on Portfolio- and Cross-Margining Programs
Aug 31, 2026
In a letter filed today with the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC), PTG expresses support for the Commissions’ efforts to expand portfolio margining and cross-margining programs. PTG argues that modern financial markets are highly interconnected and that margin requirements should better reflect genuine risk offsets across related securities and derivatives positions. According to PTG, well-designed portfolio and cross-margining frameworks can improve risk management, reduce unnecessary collateral requirements, enhance capital efficiency, and support market liquidity while maintaining market resilience.
PTG strongly recommends that access to portfolio margining and cross-margining programs should be available on a fair and non-discriminatory basis to all market participants that meet appropriate operational, regulatory, and risk-management standards. PTG notes that certain historical cross-margining arrangements, particularly involving Treasury futures and Treasury securities, were limited to direct clearing members’ proprietary accounts, preventing other qualified participants from benefiting from similar efficiencies. PTG urges the Commissions to ensure future programs provide broad and equitable access unless there is a compelling legal or risk-based justification for restrictions.
PTG also recommends that insolvency and customer-protection frameworks be predetermined and approved in advance for portfolio and cross-margining programs. Rather than revisiting legal treatment each time new programs or products are added, PTG suggests that clearing organizations be permitted to designate an approved bankruptcy and customer-protection regime at the outset, subject to regulatory approval. PTG believes this approach would provide greater legal certainty, reduce implementation delays, improve operational efficiency, and support the continued expansion of margining programs while preserving the safety and soundness of the clearing system.