Comment Text:
In regards to the proposal, my interpretation is that the CFTC is interested in laying the groundwork for consolidating the operation bodies of various financial institutions into one organization. This will impact any person or entity that interacts with the market for the worse. I do not seem to grasp the benefit of integrating separate entities under one market maker roof, likely because there is none. At least, to retail; only risks and downsides.
This proposal would enable companies or groups to integrate the processes of exchanges, brokers, and clearing houses all under one oversight. In a financial sense, the CFTC is requesting permission to become the judge, jury, and executioner without check. This proposal offers no upside for those that engage in the market, especially household investors, regardless of how hard I look over the wording.
Asking for control over all elements of a simple transaction, with no requirement to provide details for it, is exactly the approach taken by the former company FTX. In case the CFTC needs to be informed of how such an approach turned out, I refer them to the ongoing lawsuits against the former CEO.
Merging the elements of a market trade under one group's control is an invitation for market abuse, whether or not that is the CTFC's intention. Splitting up the parts of a transaction is what avoids this risk in the first place, and prevents market manipulation from growing out of control. This proposal introduces no solution to a problem. Rather, it invites a problem for everyone but market makers, who can proceed to take over the everyday trade without limit on their encroachment.
To conclude, I disapprove of this proposal, because I understand what it's introducing. It raises questions about the CFTC's interests for the broader market, who should be working towards a fairer market for institutions and households, not permitting it to monopolize. I support Chairman Christy Romero's perspective on this material.
