The "Interagency Task Force," whose report is cited above, was led by CFTC staff and included staff of the Departments of Agriculture, Energy and Treasury, the Federal Reserve, the Federal Trade Commission and the SEC. Here are some further key lines from the report, which questioned whether speculators had driven up the price of oil:

• "The key driver of oil demand has been rapid economic growth";
• "[t]he distinction between hedging and speculation in futures…

Over the last several days, we have run a number of news stories concerning the CFTC's self-evaluation and budget requests. As we noted, while the CFTC has requested a substantial budget increase for next year, including for new hires, it also has proposed to actually decrease the number of individuals involved in the economic analysis of its rule proposals. See, e.g. Chairman Gensler's Statement on CFTC Budget (with Dissenting Commissioners' Comments) Given the degree of criticism that the…

As to Form PF, I am pleased that this speech confirms my advice to clients that the Form, in unfortunately large part, makes no sense and that clients would just have to decide in some arbitrary way what many of the questions mean. While I take comfort in not being wrong on this advice (and I hope my clients will too), it is disappointing because I am sure that tens of millions of dollars has been spent gathering information that will not be comparable across funds, and that probably would…