Comment Text:
Dear Commissioners,
I am writing to express my strong agreement with the concerns and points raised by Chairman Christy Romero regarding the shift towards a vertically integrated market structure. After careful review of her comprehensive statement, I wanted to echo and reinforce some critical aspects.
1. **Protection of Customers and Financial Stability**: I wholeheartedly agree with Chairman Romero's cautious approach to any changes in the traditional market structure. Our primary responsibility remains the protection of our customers and ensuring the financial stability of our markets.
2. **Importance of Understanding Risks**: The potential conflicts of interest inherent in a vertically integrated system can't be overstressed. As the Chairman rightly pointed out, these are only the immediate risks we can identify, and there may be more risks lurking.
3. **Comprehensive Analysis Prior to Changes**: Before any shift towards a vertically integrated structure, a thorough and holistic analysis of potential risks and their impacts should be paramount. I concur with the Chairman's call for a detailed study encompassing conflicts of interest, clearing system risk, financial stability risk, and more.
4. **Consistent Regulation is Key**: The approach of "same risk, same regulatory outcome" is imperative. It ensures that we do not lower our standards or protections just because the market structure has evolved.
5. **Clearinghouses and Their Role**: The potential implications for clearinghouses in a vertically integrated structure are significant. The concerns raised regarding the disciplining effect and potential biases in a vertically integrated setup are valid and require our utmost attention.
6. **Digital Assets and Their Integration**: While innovation and progress in the financial sector are inevitable, and often beneficial, the Chairman's emphasis on differentiating between accommodating technology and adjusting the market structure is insightful. We need to tread carefully and deliberately in this rapidly evolving landscape.
7. **Collaboration and Cohesiveness**: Working in tandem with other administrative and regulatory bodies is crucial. It ensures a comprehensive, informed, and unified approach to these complex issues.
8. **Learning from the Past**: The 2008 financial crisis serves as a stark reminder of the implications of not fully understanding or underestimating the risks associated with innovative products and market structures. We should heed these lessons as we move forward.
In conclusion, I commend Chairman Romero for her meticulous and thoughtful analysis of the issues at hand. I hope that the Commission will take these concerns seriously and adopt a methodical and rigorous approach in assessing the implications of any changes to our market structure.
Thank you for considering my comments on this vital issue.
Sincerely,
James Green
