Comment Text:
I would like to under-score the comments below by Dan from CMS
If we stifle the efficiency of free markets in order to protect and preserve bureaucracy as a virtue over innovation then America has already lost
Our best and brightest minds will continue to be driven into off-shore refugee status, forcing them to innovate elsewhere, where foreign flags reap the benefits of their genius (such as has been the case with FTX / countless other major exchanges / crypto market participants) while US citizen suffer in mediocrity due to outdated rules and outdated systems
Grant them what is deserved based on the merits of their work, rather than allowing the status quo for the sake of the status quo to drive us further behind the curve and our talent will return
"We are supportive of FTX US’s proposal to offer margin directly to its users and believe that their real-time risk and margining system is superior in many ways to traditional asset class derivative exchanges. Additionally, allowing a derivatives exchange to interact directly with its user base, as opposed to being intermediated by an FCM, gives a more salient picture of risk profiles to both individual entities and the broader ecosystem. US financial markets, and particularly derivative markets, are exceedingly more liquid and higher volume producing than their global counterparts in traditional asset classes; however, looking at the global Crypto derivatives market, the US accounts for less than 5% with the only option being the CME currently. This is because new asset classes like crypto require new standards from their user base and regulators alike. By integrating their spot exchange with the proposed derivatives structure, FTX users would be able to collateralize positions in both underlying “physical” crypto as well as cash, which offers a better experience for both capital efficiency as well as risk mitigation for users hedging spot holdings in the derivatives market. FTX’s proposal gives users a superior experience to those currently available while also setting an example for what the next generation of risk management will look like for the derivatives markets."
