Comment Text:
Dear Mr. & Mrs. CFTC:
Hope all is well way back East...
The Commission recognizes that this discretionary act of clarification may result in some administrative costs to market participants.
However, the Commission believes any such costs will not be material.
Please Note: Based upon the New Jobs Act & Tax Cuts Act of 2017….when the tax rules are under construction at this point in time, the impact of changing the entity GRC (Governance, Risk & Compliance) terms on both capital expenses & operational expenses is similar to nailing a glob of jello onto a sheet of ice…..theoretically possible but not likely to work….Please review your efforts in this regard and halt making changes to the definition of terms, until such regulatory agencies, such as the following have completed their own Jobs Act regulatory Standards, Rules and Regulations….Seems like a nice idea, don’t you agree?....Also, please reduce any and all convoluted gobble-de-gook phrasing that only adds an additional layer of complexity to a taxing public business regulatory obligation which is currently undergoing renovation impacting several regulatory agencies, such as the FASB (Financial Accounting Standards Board), SEC & The PCAOB (Public Company Accounting & Oversight Board) since we all should agree that complexity is the safe harbor for back-stabbing lil weasels whose business model is FinFraud….Don’t you agree….?
Lastly, clean up any and all regulations that fail to pass the ‘Reasonable Man’ test for clarity, subjectivity, et al providing real-world---step by step formulaic examples for each industry impacted by same…..as according to one EY report, in 2013, the CFTC’s sample formula was and is pretty much ignored…as a ‘standard baseline’ for making such regulatory calculations….as our understanding of formulaic means step-by step and NOT open to interpretation at each step of the process/protocol….Please correct us at your convenience…..Lastly, lastly, please remove all subjective---open to interpretation words, terms, phrases such as; however, appropriate, exemptions, except, et al….)Respectfully yours, Pw Carey
