Comment Text:
I wish to respond directly to two of your questions:
Would an effective date that is 30 days after publication of the final rule amendments in the Federal Register provide registered entities with sufficient opportunity to comply with the amendments?
No, a 30-day effective date would likely not provide registered entities with sufficient opportunity to comply with the amendments. Regulatory changes often require substantial adjustments in operational processes, systems, and compliance protocols. Registered entities need adequate time to interpret the new rules, train staff, update internal systems, and ensure that they meet all new requirements without causing disruptions to their ongoing activities. A 30-day window is typically too short to accomplish these tasks thoroughly, potentially leading to compliance issues and operational risks.
Would the proposed 60-day implementation period provide sufficient time for the expiration of, or orderly cessation of trading in, listed event contracts that are impacted by the proposed rule amendments?
No, a 60-day implementation period will not be sufficient for the expiration or orderly cessation of trading in listed event contracts impacted by the proposed rule amendments. Event contracts often have varying durations and complexities that require careful management to unwind or transition. A 60-day period may not account for the contractual obligations and market practices associated with these contracts. Ensuring an orderly cessation of trading necessitates a more extended period to avoid market disruptions, protect market participants' interests, and maintain overall market stability.
Finally, I add one more comment here. a 60-day comment period is much too short for this comment period on event contracts. This process has been rushed. There has been no engagement with stakeholders. There has been no roundtable. There has been no concerns cited by the CFTC. This proposal is purely political and it is a significant rulemaking that warrants more time for commenters.
