The MF Global fraud of 2011 is especially noteworthy not only for its size, $1.6 billion, but for the effect it had on regulators in the futures industry (Duffy 2012). MF Global was, as its name implies, a worldwide derivatives and commodities brokerage firm (Wikipedia undated). In late October 2011, the company suffered a major financial meltdown following the misappropriation of more than $891 million in customer funds thanks to CEO Jon Corzine’s attempt to cover up losses from European sovereign debt. By the time the company declared bankruptcy on October 31, the shortfall in customer accounts totaled at least $1.6 billion. To reduce the risk of future frauds, the CFTC and its self-regulatory body, the NFA, decided to require companies in the futures industry to undergo electronic audit confirmations of customer account balances. The NFA then mandated that its staff use Confirmation.com. Fox, the founder of Capital Confirmation, Inc., told the lead author of this article during a phone conversation that the NFA first contacted him in mid-2011, months before the MF Global fraud was uncovered. This suggests that the NFA was already trying to find a better way to audit cash balances. Unfortunately, it was too late; other frauds were under way