Sara,

I concur totally with Paul.  I did some work re the OMLX as a clearing house 
when we prosecuted ENA's membership of the OMLX.  As comes through in Paul's 
note, what is crucial is to ascertain is:

Is one's collateral, etc., properly segregated from one's clearer's assets on 
the one hand, and also from the clearing House's assets on the other hand, 
under the locally applicable insolvency provisions??????

As Paul says, if you would like to contact Paul or Ed on this please feel 
free - I can also assist you if you would like me to.

Kind regards

Mark    




Paul Simons
05/23/2000 11:14 AM
To: Sara Shackleton/HOU/ECT@ECT
cc: Mark Elliott/LON/ECT@ECT, Justin Boyd/LON/ECT@ECT, Edmund 
Cooper/LON/ECT@ECT 

Subject: Re: global futures exchanges  

No, but we have considered recently our exposure to brokers where they hold 
our money.  The analysis is more a function of applicable law/regulation (SFA 
or CFTC rules) than clearing house rules as I understand it.  We did not take 
outside advice or prepare memoranda, but Justin may have done so in the past 
(Justin?).  Please call me or Ed if you'd like to discuss.

Paul


From: Sara Shackleton on 22/05/2000 11:19 CDT
To: Mark Elliott/LON/ECT@ECT, Paul Simons/LON/ECT@ECT
cc:  

Subject: global futures exchanges

Mark and Paul:  Have either of you ever reviewed clearinghouse rules with 
respect to clearing members for the exhanges on which we trade (in an effort 
to analyze our risk with respect to our brokers)?  If the answer is yes, 
could I have copies of any memoranda?  Please let me hear from you or 
whomever may have reviewed this issue.  Thank you.  Sara