[count-your-change]

The one important question I think I could ask about commodity futures margin requirements is: Do they perform their intended purpose? If they do, why change them? If there are abuses go after what produces them not something that does what it was intended.
Why shoot groundhogs when it’s the deer eating my garden?
Cause they’re easier to hit I guess.

[SAJ]

With the introduction of the SPAN margining procedure in the late 1980s, futures margining has become really quite efficient. I'd say the process is very well suited to the task and does it well.

The abuses in present-day futures mkts have absolutely nothing to do with margining, zip, zero, zilch. The abuses are right now caused by people using existing law (and existing regulations) to game mkts.

The 'groundhogs' at whom the Regress and CFTC need to aim are the investment banks, who are deliberately abusing the current system. Unfortunately, in the case of the Regress particularly, it's not considered sporting to shoot at those who own you.

More's the pity.