From this article:
http://www.lexology.com/library/detail.aspx?g=2d2528a7-e564-4b56-bc06-232df63d4b2b
The quote that makes me think twice:
"A DFP Guarantor would be authorized to prescribe risk controls for its DFP at CME Group exchanges, including credit controls, increased margin levels and concentration limits, among others. A DFP Guarantor could perform back-office functions for its DFP"
So a clearing member that guarantees risk for a DFP is "prescribing" risk controls" for the same DFP? I may be missing something, but seems like a conflict of interest. I guess I would have to better understand the level of authority that "prescribing risk controls" actually entails.