On November 1, the CFTC Division of Clearing and Risk issued a staff interpretation letter which clarifies certain operational issues regarding the implementation of Part 22.  Under Part 22, Futures Commissions Merchants and Derivatives Clearing Organizations must legally segregate each Cleared Swaps Customer’s collateral, but are permitted to operationally commingle the collateral of their Cleared Swaps Customers.  CFTC Interpretation.