Comment Text:
The proposed collection of information is necessary for the CFTC and will have practical use, IF the CFTC would choose to engage in enforcement actions against malicious actors. This data must be reported and analyzed as it is a national security risk to allow a single party to become a systemic risk via over leverage using futures trading. Without this information malicious actors could use futures trading to over leverage themselves to the point of systemic collapse resulting in a loss of faith in the US Futures Market.
The accuracy of the CFTC's estimate of the burden of the proposed collection of information is laughable. Self reported time spent organizing and collecting this data is not the proper method to obtain this information. The CFTC should not be using self reports on the time burden of the collection of data. The reason this data cannot be trusted is that participants that respond to the CFTC survey have a conflict of interest in over reporting time spent collecting and organizing data to falsely induce the CFTC into relaxing reporting requirements as they can claim its too burdensome.
To enhance the quality, usefulness, and clarity of the information to be collected the CFTC should work directly with the DTCC to ensure the number of futures contracts is linked 1 to 1 to the number of shares available.
Ways to minimize the burden of collection of information
on those who are to respond, including through the use of appropriate
automated electronic, mechanical, or other technological collection
techniques or other forms of information technology; e.g., permitting
electronic submission of responses.
Ways to minimize the burden of collection of information on those who are to respond would be to ensure that all futures transactions are made on a block chain where all information is logged automatically with every trade effectively reducing their burden to 0.
Regards,
Anthony
