It is all to the good that FSOC has removed all SIFI designations. It would be even better if Congress would repeal those provisions of Dodd-Frank allowing FSOC to designate institutions as SIFIs on the basis of standards that are completely open-ended and discretionary. Financial regulation, indeed regulation of any kind, ought not to operate on the basis of discretionary standards. See, e.g., .

This is a good letter. There has been an unfortunate recent legislative and regulatory tendency to push responsibility up to an entity's board of directors, or chief executive officer, even where the matter did not require such high-level attention. Elevating matters inappropriately just detracts from the ability of senior management to do their real jobs. This letter is a good step in the opposite direction by allowing an appropriate delegation of responsibility.

This is a good letter. There has been an unfortunate recent legislative and regulatory tendency to push responsibility up to an entity's board of directors, or chief executive officer, even where the matter did not require such high-level attention. Elevating matters inappropriately just detracts from the ability of senior management to do their real jobs. This letter is a good step in the opposite direction by allowing an appropriate delegation of responsibility.

Chair Giancarlo explained that his predecessor had taken a very aggressive stance as to the scope of U.S. regulation. Former Chair Gensler effectively asserted that the Europeans would have to implicitly consent to complying with CFTC regulations if they wanted to do any business involving U.S. businesses or markets. The Europeans appropriately, and successfully, pushed back on this proposition.

When Mr. Giancarlo assumed the role of CFTC Chair, he completely, and…