This relief may seem technical, but it is highly material to FCMs who otherwise would be required to tie up their proprietary cash needlessly during the business day. As, the number of FCMs has declined substantially in the past several years. The decline likely is driven by increased regulatory costs and burdens, and decreased revenue opportunities. This relief is a step toward righting that wrong direction.

The number of futures commission merchants has declined steadily, . The incoming regulators may be reasonably concerned about this exodus from the industry. It is not possible to say the extent to which the decrease in the number of firms is due to increased regulatory costs, but it would be surprising if that were not a material factor.

Given CFTC Chair J. Christopher Giancarlo's concern over the rights of market participants to protect their intellectual property, comments on Regulation AT should be read with an open mind.

The substance of Chair White's advice and commentary seems Delphic. Is she telling her successors to be independent of the new administration of the President-elect, or is she articulating her stance toward Senator Elizabeth Warren's various attacks? (See; ; .)