The SEC and CFTC’s Review of Portfolio Margining Rules 

Chris Horril
SEC and CFTC seek comment on harmonizing portfolio margining across securities and derivatives. See what cross-margin reform means for your firm.

US regulators are opening a review of margin regimes across derivatives and physical securities, and the direction is clear: wider adoption of portfolio margin methodologies, with an eye toward consolidating regimes that have long been kept apart. The joint SEC and CFTC request for comment issued on June 26 is the clearest sign yet of that shift. The two agencies are asking whether portfolio margining should be harmonized across securities, security based swaps, and futures, with the comment window open for 60 days after Federal Register publication. 

The problem they are trying to fix is this: A firm trading listed futures alongside OTC swaps, or cash equities and their derivatives, often has to post margin on each leg separately, in separate accounts, under separate rules. Risks that would net out economically don’t net out in real life, because the SEC and CFTC never fully aligned their risk calculations. SEC Chairman Paul Atkins said cross margining “offers a clear opportunity to unlock liquidity that remains frozen in separate accounts.” CFTC Chairman Mike Selig called it a chance to “unleash untapped capital.” 

That’s a notable admission: two regulators saying, jointly, that their own rules trap capital unnecessarily. The securities and derivatives divide, drawn decades ago, no longer matches how portfolios are managed today. 

The request covers margining models, cross product offsets, collateral treatment, and customer protection. That last point matters most, since netting exposures across regimes only works if firms can unwind those positions safely under stress. 

If this review leads to a more flexible margin regime, both buy side and sell side firms will need to calculate portfolio margin across a much wider set of instruments, OTC and physicals together, not just for current portfolios but for hypothetical what-if scenarios too. They will also need a way to allocate that margin across a larger instrument set to support internal chargebacks and profitability calculations.  

This is exactly what Atoti, ActiveViam’s AI-native risk management platform, is built for: aggregating exposures across products and regimes in real time, running what-if scenarios on demand, and allocating margin down to the desk or position level. Firms that already manage risk this way are ahead of where the rules are heading. 

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