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Comment for Proposed Rule 81 FR 36484

  • From: Peter Schwartz
    Organization(s):
    www.systemicriskregulation.com

    Comment No: 60828
    Date: 6/13/2016

    Comment Text:

    Executive Order 13576 of June 13, 2011 ( precisely 5 years ago from today)

    My Administration is committed to ensuring that the
    Federal Government serves the American people with the utmost effectiveness
    and efficiency. Over the last 2 years, we have made good progress
    and have saved taxpayer dollars by cutting waste and increasing the efficiency
    of Government operations by curbing uncontrolled growth in contract spending,
    terminating poorly performing information technology projects

    The American people must be able to trust that their Government is doing
    everything in its power to stop wasteful practices and earn a high return
    on every tax dollar that is spent.

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    In his opening remarks, Commissioner Giancarlo expressed concern that the CFTC does not yet fully understand the implications of the new digital trading environments and cautioned that Regulation AT is “a 20th Century analog response to the 21st Century digital revolution in trading markets.”

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    Regulation AT of Fried Frank Harris Shriver & Jacobson LLP per their article in Lexology 12/8/15:

    “Despite various statements that this rule proposal largely mirrors existing industry best practices and embodies a principles-based approach rather than a set of prescriptive rules, it is difficult to avoid concluding that, if adopted, Regulation AT would impose substantial additional compliance and risk management costs on market participants, including asset management firms who are registered as CPOs and/or CTAs, without necessarily generating adequate countervailing benefits for transparency or market integrity.”

    “There is no dispute that market participants should have appropriate risk controls. The issue is whether this objective can be accomplished more effectively and efficiently by supporting ongoing industry efforts in this area, instead of adding a panoply of detailed compliance, reporting, and related requirements.”

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