On November 18, 2016, the CFTC will cease issuing Special Calls via the legacy Form 40/40S and begin issuing Special Calls using a new, electronic filing, submitted directly to a CFTC database (the "New Form 40/40S").

"The Risk Desk" editor John R. Sodergreen described the debate between CFTC Chair Timothy Massad and Commissioner Chris Giancarlo over an amendment to proposed Regulation Automated Trading that would allow the CFTC access to an algorithmic firm's trading source code without first issuing a subpoena.

"CAN THE CFTC SEE THE BIG PICTURE?" In a speech delivered before a gathering of ISDA members, CFTC Commissioner Scott O'Malia reviews the agency's implementation of Dodd-Frank mandates and highlights his concerns, including the lack of robust cost/benefit analysis in Dodd-Frank rulemaking.

CFTC Speeches CFTC Commissioner Brad Chilton, in remarks delivered at the Institutional Investor TraderForum calls for regulators to consider whether there should be limits on advanced analytic trading and imposition of legal responsibility on high frequency and algo robot trading that roils markets and causes concerns and obstacles for traditional traders. "I think those who instigate runaway high frequency or algo robot trades should be held accountable when they hurt other market participants or injure consumers." Chilton also advocates imposing "reasonable fees" upon the industry if the

"Expect the Unexpected", Speech by CFTC Commissioner Bart Chilton September 9, 2011 In a wide-ranging speech, CFTC Commissioner Bart Chilton, a Democrat, claims that the economic meltdown of 2008 was caused by "government getting out of the way." He observes that today "this industry, this exchange-trading of swaps, will be built from the ground up." with statutory dictates and new government requirements for "swaps execution facilities" and "swaps data repositories," and that "all of these entities-and the participants-will be registered with the Commission and will require staff to ensure