NGFA's recommendations included: - Daily reporting of segregated fund investments and positions by futures commission merchants (FCMs). - More detailed and frequent audits of FCM reports, including "unannounced spot checks" of FCMs. - A "rigorous review" of FCM and broker-dealer capital requirements by CFTC - Scrutiny by CFTC of the practice of double-counting such required capital when a firm operates as both an FCM and a broker-dealer. - Specific signed and transparent documents from FCM executives when segregated customer funds are moved to non-customer accounts in order to "assign accountability and to aid in establishing that fraudulent activity has occurred." http://www.reuters.com/article/2012/04/05/us-grains-mf-global-idUSBRE8341DG20120405