Comment Text:
The publication of COT data, in the new format, provides transparency on the futures markets. Transparency and openness in futures trading is a good thing. The more transparency the better. The new format which includes Swap data is invaluable for me as a futures trader. Please continue to provide this information.
With an eye on the Federal Deficit, I would be willing to pay a small fee for this information (e.g. $150/yr). I also feel the fee could be charged on a sliding scale. The large swap traders, the ETFs and retirement funds could afford to pay a larger fee for this information.
Alternatively, the CFTC could assess a fee on the exchanges. I pay a fee to the exchanges every time I make a trade. Increasing the fee by a few pennies per trade would not hurt the average trader but would benefit the CFTC and help reduce our National Debt.
With regard to margins; for me, the margins are affordable and allow me to utilize furtures trading as a hedge against other investments. However, raising the margin, generally, may price me out of this investment vehicle. If there is a plan to charge swap dealers, or ETFs a different margin than the small trader, I feel this is unfair and could skew the markets.
Alternatively, swap dealers, ETFs, Large Traders might be charged a fee by the CFTC based on the numbers of Swaps, trades, etc. However, again, altering the fees charged for participation in the Futures markets may alter the number of participants, or the value of their participation, therby altering the way the markets behave. As a small trader, I am only now beginning to understand the impact of SWAPS on market movements. Altering the behavior of the particiapnts by raising margins may be a negative influence on the markets.
Alternatively, the very large dollar SWAP dealers could simply create an alternative derivatives market to trade off. Then where would we be?
Thank you for all the work the CFTC staff completes.