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CFTC Chief of Staff Describes Approach to Leading the KISS Initiative

CFTC Chief of Staff Mike Gill discussed CFTC Acting Chair J. Christopher Giancarlo's commitment to reviewing rules that might hinder market growth and liquidity, and to do away with those that are unnecessary or overcomplicated. Mr. Gill has been designated to lead Project KISS ("Keep It Simple, Stupid") the agency's regulatory reform initiative. He also directs the internal review task force.

Risk Desk editor John Sodergreen summarized several considerations around the KISS initiative (see also previous coverage) and Mr. Gill's approach to "poorly designed rules" that are applied in a "needlessly complex manner." Mr. Sodergreen emphasized several points made by Mr. Gill at a recent FIA Conference. On the intent and scope of the initiative, Mr. Gill stated:

"[O]ur aim is to identify duplicative examinations, duplicative document requests, out-of-date file formats and forms. Please suggest technical amendments to codify existing relief, modernize rules and allow technology-neutral compliance. We would also like suggestions that would clarify and simplify rules and ease burdens and promote efficiencies."

Mr. Gill said that the CFTC already has identified 35 existing regulations in need of modernization, and anticipates expanding the initiative in the coming months. He stated that in addition to pinpointing rules to simplify and update, the CFTC is focused on codifying longstanding no-action letters in areas where full compliance is not possible, such as swap confirmation and affirmation timing.

The CFTC is requesting comments on Project KISS. Comments must be submitted by September 30, 2017.

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