Among the questions asked by the CFTC are whether the proposed contracts are "contrary to the public interest." of the CEA provides that the CFTC may reject a contract if it involves "similar activity" to the other items listed in Section 5c(c)(5(C); e.g., war, but it does not give the CFTC an open-ended right to reject contracts based on the Commissioners' judgment that the contract would be contrary to the public interest. Given that elections do not, at least so far, resemble war,…

The "strategic plan" is ultimately a political document rather than a substantive regulatory plan. No one quarrels with the goal of protecting retail investors and the SEC's systems, or with the concept of investor outreach.

In Chair Gary Gensler's months as head of the SEC, the agency has put out an unprecedented number of new rule proposals. The generic goals in the strategic plan seem intended to be a justification for all those proposals. But, at a more specific level, it is…

Comment letters to the SEC by industry associations usually provide some criticism of the likely burdens of new regulations; however, industry participants are generally cautious of being viewed as oppositional by their regulator. This letter is therefore notable in both substance and tone, and for its discussion of potential administrative procedure failures of the proposal.

SEC Chair Gary Gensler's aggressive program of rulemaking has pushed the boundaries of statutory authority in…

The recipients of the letters are a somewhat eccentric collection of businesses. A number of the recipients were actually providing false information about other sites with which the recipients have no obvious connection. For example, lists 10 crypto exchanges that it claims are FDIC-insured. FDICCrypto redirects to , which seems to be a combination of a limousine service, crypto business and music site. An interesting business mix.