CFTC Notice: Agency Information Collection Activities under OMB Review (with Lofchie Comment)

The CFTC has announced an opportunity for public comment on the proposed collection of certain information by the agency. Under the Paperwork Reduction Act, Federal Agencies are required to publish a notice in the Federal Register concerning each proposed collection of information, including each proposed extension of an existing collection of information, and to allow 60 days for public comment in response to the notice. This notice solicits comments on collections of information provided for by the Disclosure and Retention of Certain Information Related to Cleared Swaps, Customer Collateral.

Comments Due: December 3, 2012.

Lofchie Comment: It is ordinarily the case that notices with respect to record keeping pass unnoticed, based on the reasonable assumption that the regulators will ignore any comments. In the case of the records required by Dodd-Frank (not only the ones required by CFTC Part 22, which requirement is the particular topic of this proposal), it seems to me that it could be worthwhile to comment given the incredible disparity between the amount of records and reports required by the regulators and the expense of producing, providing and maintaining those records, on the one hand, and the ability of the regulators to make any use of them, on the other.

View notice in full here: 77 FR 60114.