Comment Text:
Thank you for taking feedback on this topic.
I almost tried to answer each question individually, but then I took a step back and thought, "what is even the purpose of any of this?"
Look back at the historical need for commodities futures. That makes some sense. A farmer might not be able to afford to plant crops and do all the work that leads up to when they get paid at harvest. Commodity futures allow them to have the opportunity to lock in a price and get much needed liquidity to do their job. The same can be said for any other commodities that involve a lot of upfront capital and risk.
What percent of trading regulated by CFTC actually falls into this category? What societal needs are met by those that don't? How many commodity futures traded actually get delivered, and what percent of traders are even prepared to take delivery of something they actively trade? I'd be willing to bet it's in the single digits.
With that having been said, what value to society is there in the vast majority of "financial products" that CFTC regulates, and what value to society has CFTC provided in such regulation? Will CFTC's actions prevent the next financial catastrophe related to derivatives trading? If the answer can't be clearly and easily answered, maybe it shouldn't exist to begin with.
Perpetual style derivatives are just another example of shady manipulators looking to add complexity to a system to justify taking money away from ordinary people. Look at the notional value of derivatives worldwide vs. the total amount of money in existence worldwide, and tell me with a straight face that there isn't a problem, and that I can trust your organization to adequately protect the American people from financial harm if the whole thing blows up.
Given the number of questions on the request for public comment, it's clear that your organization isn't prepared to understand or regulate perpetual style derivatives. I don't think anyone would be, so don't take that as an insult to the commission. Perpetual style derivatives are meant to be opaque and impossible to regulate by design.
If you want to set the CFTC up for success, simply don't allow them.
Thank you for your time and consideration.
