Comment Text:
I am very surprised that the CFTC considers this rule filing novel in any aspect. The CFTC hasn't stated why it's novel, but it's hard to guess what this rule does that the CFTC has not seen every time it looked at other exchanges for years. The same goes for the potential that the rule is inconsistent with the CEA and regs. If this rule is inconsistent, CME, Cboe, and ICE better be working on changing a lot of things about their rules.
On the whole, it's very obvious that the rule is consistent. It also does none of the things that Better Markets (sic) says that it does.
