This is a significant move by the CFTC. It improves relationships with the Europeans and it accomplishes Chair Giancarlo's goals of facilitating the ability of firms to transact globally. It undoes the geographic market fragmentation that had resulted from the post-Dodd-Frank regulatory regime. The next priority should be to improve the rules for trading on U.S. swap execution facilities. Such a step would benefit the competitiveness of the United States as a financial center.

If the swap dealer de minimis threshold were to drop, every swap dealer that does between billion and billion of business would either stop dealing entirely or drop its dealing activity below the new threshold. While those numbers sound large, in reality, the way in which the calculations are done makes it a generally very small number, particularly in economic value. Any firm doing less than billion of swap dealing business is not a remotely meaningful participant in the swaps dealing…

These proposals aim to improve the U.S. public capital markets so that more issuers may be willing to raise money in these markets. It is now the task of both issuers and investors to review the proposals carefully: (i) issuers to determine whether the rule changes would continue to provide required information and do so at a reasonable cost, and (ii) investors to consider whether the proposed rule changes would result in the loss of information that is material to an investment decision.…

The prior Administration viewed financial markets as creators of risk that had to be controlled; this Administration appears to view financial markets as creators of growth that would benefit from decreased controls. This is simply a tremendous difference in perspective and tone.

There will and should be a fair amount of discussion over these many and specific recommendations. One broad recommendation, however, stands out: restoring to both the SEC and the CFTC complete exemptive…