Since he assumed office, Chair Giancarlo has emphasized that derivatives should not be treated as a scapegoat for the 2008 market crash and that, contrary to some popular opinion, by far the largest use of derivatives is not for financial speculation but for commercial hedging. By highlighting these points, Mr. Giancarlo argues that the regulation of futures and swaps should be driven by economic considerations and not by domestic politics.

During the delay period, we expect that FINRA will also reconsider the substantive requirements of the rule.