Comment Text:
I write separately from my main comment because I don't want to prejudice you against what I have to say. The CFTC should consider adopting the practice of other agencies and not try to fool the public. Be forthright with your regulator proposals, and don’t hide the ball. The analysis throughout this proposal is filled with misdirection, half-truths, and selective omissions. I don't recall ever seeing anything like this from DOL, ED, Treasury, etc. before in my more than 45 years of practice.
