Comment Text:
I write in opposition to the comment submitted by Steve Suppan on behalf of the Institute for Agriculture and Trade Policy (“IATP”). The IATP comment misunderstands basic tenets of administrative law. It excuses the CFTC's failure to consider relevant information that it requested on some of the contracts that it is proposing rules on, on the basis that the rule covers additional contracts as well. That is so laughably wrong that I was compelled to comment. The CFTC does not get a hall pass from its basic reg writing requirements because it proposed an ambitious rule. Instead, it increased it. The CFTC was required to consider those comments on election contracts, without a doubt, and is also required to consider the relevance of those contracts to the rest of its proposal. The IATP comment seems to miss this obvious point, so I thought I'd point it out.
