Other firms undoubtedly will seek to apply the new procedures provided in this guidance to their own activities. Given the high potential liability for getting it wrong, firms should stay within the four corners of the no-action letter, or seek relief tailored to their different individual circumstances.

It is notable that Mr. Fleming did not focus on disclosures of political and political-interest issues, such as those favored by  (D-MA). Instead, Mr. Fleming concentrated on disclosures that facilitate investment decisions.

Mr. Luparello has broad experience in financial market regulation and is highly respected. His departure will be a loss to the SEC.

If ever a rulemaking reflected the triumph of political ideology over economic reality, it is the position limits proposal. It should be obvious to all by now that the price of energy is not driven by "speculation" but by world events, such as potential war in the Middle East, developments in Iran, Russia and Venezuela, economic activity in China, and the development of fracking. CFTC Chair Massad should at least admit the possibility that the rulemaking was ill-conceived or, failing…