Very few derivatives have a term to maturity that is so long that climate change is a material risk embedded in the contract.  If the CFTC is looking for materials risks to attend to (although these are also risks as to which it lacks express authority,) perhaps they can turn to regional conflicts and supply chain disruptions.  

"Investor protection, not issuer protection" is a nice line, but it ignores the fact that investors pay for burdensome regulation. The legislators might also consider whether excessive regulation is in any way related to the diminishing number of public companies in the United States. It is likewise not the case that the regulators should be guided by a count of letters from the public. They should be guided by cost-benefit analysis that ideally makes a realistic assessment of costs.…

Mr.Uyeda's comments are, in good part, a criticism of the SEC's proposed adoption of climate change disclosure requirements for public companies. The SEC appears committed to that additional (expensive) disclosure requirement and .

Although the Congressmembers are undoubtedly right that putting custodied digital assets on balance sheets would discourage banks from providing custody for such assets, SAB 121 was not the basis for the bankruptcy court's decision. The court reached its conclusion on the basis of the contract between the account holders and the custodian.  

The accounting treatment of digital assets should follow from the terms of the custodial contract and the custodial procedures, and…