Letter 14-126 should be revised to drop the common control requirement. The CFTC has from this requirement, and it does not seem to serve a material purpose.

Presumably, concern over crypto products, and the uncertain regulatory status of these products, loaned some urgency to this agreement.

Firms should give consideration to the documentation requirements of the proposed rule, particularly the requirements that would apply to proof of the grant of discretion to an outside adviser.

SEC Commissioner Peirce's remarks should be the starting point for a real dialogue about the future of the SEC.

provides, "Whenever . . . the Commission is engaged in rulemaking and is required to consider or determine whether an action is necessary or appropriate in the public interest, the Commission shall also consider, in addition to the protection of investors, whether the action will promote efficiency, competition, and capital formation."

The SEC ought to be considering…