It is difficult not to feel sympathy for Chair Massad. It is a tough budgetary situation. Considering the CFTC's enhanced responsibilities, the expansive rulemaking that has taken place over the last several years and the seeming lack of regard for the costs of implementing those rules, a zero budget increase is a serious problem.

The CFTC should consider scaling back on regulatory requirements that serve no material purpose. A good place to start is CFTC's double regulation of SEC…

This is actually a report that poses good questions. It is not a generalized attack on non-banks that raise money or lend it. Rather, it is a discussion of the relationship between banks and non-bank entities with which the banks have some affiliation, such as sponsored money market funds or conduit financing vehicles.

Historically, FINRA's mark-up rules had not applied to government securities, either because the SEC was deferring to the authority of Treasury, or because of a more general concern that applying any requirements to government transactions would damage the liquidity of the market. While there are certainly many places where legitimate concerns of bad rules damaging the market should be taken very seriously, this is not one of them. There is no reason that retail investors should not be…

Kudos to the current Commissioners for doing a bit of clean-up. Hopefully, more of this to come.

As to the deletion of the requirement that pre-trade oral communications be traceable to a particular transaction, the release states (at page 7): the CFTC "noted that access to searchable pre-trade communications is an important element of its oversight of the derivatives market and enforcement of Commission rules and regulations. The Commission recognized, however, that keeping these…