Comment Text:
The National Rural Utilities Cooperative Finance Corporation (CFC) has submitted several comments to the CFTC related to the points made in this submission. This document summarizes those major points and, in one document, includes all of the precise recommended rule changes already supplied to the CFTC (and other agencies, as appropriate).
As CFTC thinks about its plans for a retrospective review of regulations, we note that CFTC and other federal agencies should pay special attention to very specific exclusions or other precise indications which Congress has included in laws.
Those specific references are at times included because Members of Congress have concluded that previous rules of the agencies were not consistent with Congressional intent of prior laws. Or, those specific references are inserted to provide direction to the implementing agencies -- to permit the agency to correct approaches. As rules are retrospectively reviewed by agencies, it may become apparent that such direction by the Congress should govern that analysis also.
Thus, as the CFTC does its retrospective review, we urge them to consider the comments in the attached document which focuses on a very specific provision of the Dodd-Frank Act that shows a clear Congressional interest in providing CFTC with the authority to take into account the public interest benefits and purposes of the nonprofit rural electric cooperatives and their wholly owned, nonprofit CFC.
