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Comment for General CFTC Second Voluntary Carbon Markets Convening on July 19, 2023

  • From: Daniel Owen van Dommelen
    Organization(s):
    None

    Comment No: 72740
    Date: 7/25/2023

    Comment Text:

    I join Andrew Robinson in the viewpoints expressed in his comment. Having done nothing but research this since February, I can only say that I have encountered more than a decade's worth of mentions about needing "more regulation" and of course "transparency". If by transparency we mean "out in the open" sure, it is transparent. However, the trick has become to oversaturate, build up hundreds of small funds, medium funds, large funds, trusts, companies, mergers, "strategic partnerships" all producing tens of thousands of documents that are hundreds of pages long. By the time you catch up, they will have already pivoted the market to another new and shiny financial instrument, or have collaborated to build a market somewhere else.
    While meetings are being held, and task-forces created, they build ten new exchanges in China.
    They build crypto-based platforms. Registries that are obscure, however receive plenty of traffic.
    For sure the APX/XPansive markets can move credits between them, as they are all really the same platform, but then they all have a separate format for serial numbers, so one inter-registry trade and the obscuring process begins.
    Meanwhile brokers like South Pole claiming to have sold "only" 23 million of faulty Kariba credits actually has sold over 87 million, and that is according to their own database.
    With climate finance, unregulated markets, and the blending of corporate, private, and public funds, the super wealthy have finally found "the greatest financial instrument ever invented".
    It only exists on paper, and even there it still means nothing.
    Banks, oil companies, hedge funds, and the other assorted wealthy are what makes up most of what we are betting the climate on.
    And the "suckers" like me who they hire to "work" for them, like a hamster in a wheel, keeping whatever your can spinning so it looks like there is a real company, and not some front where the real business happens at the top that is in it for the real money, coming from trading, blending in their private wealth, then releasing "financial statements" where they live just at the edge of the law in what they can openly decide not to report. Look at any of the "not for profits" there is no mention of which money is public, and which is private. Now, how will you tax this?
    Exactly.

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