Comment Text:
Dear sir/madam,
I firmly take the perspective of Chairman Christy Romero's comment posted at the following link.
https://www.cftc.gov/PressRoom/SpeechesTestimony/romerostatement062823
The potential new vertical integration of clearinghouses with the customer facing intermediaries will not promote market stability, investor protection, or reduced market risk. This new regulatory framework should not be implemented under any circumstances. It only serves to hand over the ability of substantially more risk and leverage to a vertically integrated (see: monopoly) clearinghouse, with a significant reduction in seeing both the level of risk and the ability of a naturally occurring disciplinary feedback mechanism to be in place.
This vertical integration poses additional risks with absolutely no benefit.
This new regulatory proposal should not be implemented in any fashion, and only serves to hand over more power to clearinghouses, eliminate their competition, and allow them to make more money through poor trade fulfillment and questionable margin requirements or structure, at the expense of additional risk, contagion, and cascading losses that investors and customers will ultimately take the losses for.
Best regards,
MS. WEI TAN
