Client money would be placed in a pool, of which Goldman would be the trustee, to be held by a third party exchange, clearing house, or intermediate broker. The client is still exposed to market risk, but not the risk of the individual firm. ‘Client money’ regulations in the US and the UK regulatory environment mean that client margins are held in segregated ‘client money’ pools and are not exposed to the clearing broker’s balance sheet.

It is understood that in several of the struggling US investment banks these rules were neglected, and on occasion client money was used to shore up balance sheets. Historically the over-the-counter derivative markets have not been highly regulated. Goldman suggested that in the future, strong regulation from the agencies within each jurisdiction would evolve, bringing with it mechanisms for greater client protections.