Commissioner Giancarlo's remarks are positive, given that he must work within the existing Dodd Frank legislation. Under prior management, the CFTC managed to take a bad piece of legislation and turn it into rulemaking that proved to be even worse. Under new management, which understands the benefits that hedging through swaps provides to the financial markets, and which does not bear the burden of having to justify flawed rulemakings from the past, material regulatory progress is possible…

Political contributions, like personal investment decisions, are subject to strict control processes and must be made in light of those processes.

That regulators should be required to take the costs and benefits of their rulemakings into account seems entirely reasonable. The questions that arise are these: (i) how quantifiable are these costs and benefits in reality, and (ii) how seriously will regulators take the cost-benefit analysis requirement? In his farewell remarks, outgoing Department of Labor Secretary Thomas Perez asserted that the DOL's new fiduciary rule would save investors seventeen billion dollars a year.…

The Commodity End-User Relief Act fixes a number of serious problems including the difficulty of utilities' search for swap counterparties; the need to trade-report illiquid positions; and One provision that could be interpreted as increasing risk is the treatment of residual interest, but the relevant provision will lower the costs of operating as an FCM materially (which is a very good thing considering the number of FCMs that have gone out of business since Dodd-Frank).…