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Comment for General CFTC Request for Comment on the Impact of Affiliations of Certain CFTC-Regulated Entities

  • From: Hussain Shahabuddin
    Organization(s):
    Household Investor

    Comment No: 73016
    Date: 8/27/2023

    Comment Text:

    Dear Commissioners,

    I am writing to reiterate my concerns, as previously outlined in my comprehensive comment letter, regarding the proposal under consideration. Additionally, I would like to emphasize the pivotal role that the Commodities Futures Trading Commission (CFTC) should play in safeguarding the integrity and transparency of our financial markets.

    My primary concern centers on the persistent lack of transparency and the obscured nature of critical data, particularly concerning swap transactions. The recent debacle involving Archegos Capital Management and its associated swaps serves as a stark reminder of the potential consequences of such opacity. The losses incurred by counterparties were staggering, pushing major brokers and clearinghouses to the brink of collapse and triggering contagion that spread to influential banks. This alarming scenario must not be allowed to recur, and proactive measures are imperative.

    As a regulatory authority, the CFTC holds the responsibility to proactively identify and address instances of overexposure and excessive leverage that could threaten the stability of our financial markets. The current state of affairs, wherein essential swap data remains concealed from public scrutiny, is untenable. Investors deserve full transparency into potentially deceptive practices, and the CFTC must possess the means to enforce corrective actions with the full force of regulatory authority.

    It is with a sense of disappointment that I observe instances where the CFTC appears to have turned a blind eye to these critical regulatory concerns. Mere fines and penalties that amount to little more than the cost of doing business are insufficient deterrents. The status quo of routine tasks and a lack of decisive action fall short of the robust oversight that is necessary. The time has come for the CFTC to assert its authority over dominant market participants, hedge funds, clearinghouses, and others, to expose and rectify fraudulent and deceptive practices that present an existential threat to the financial well-being of investors and the broader market. Proposals of this nature make me concerned about the direction and capability of the CFTC to adequately address pressing issues. As a citizen, I trust that my voice will be duly considered, and I earnestly hope that my concerns will be alleviated through the Commission's forthcoming actions and proposals.

    In conclusion, I urge the CFTC to not only consider my previous comment letter but also to take assertive action in addressing the pressing issue of transparency and data obfuscation. The potential risks to our financial system demand an unwavering commitment to accountability, transparency, and vigorous enforcement of regulatory mandates.

    Thank you for your attention to these vital matters.

    Sincerely,
    Hussain Shahabuddin
    Household Investor

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