The NFA's attempt to align its reporting requirements with those of the CFTC is a welcome development, and firms will similarly welcome deferral of the new CTA quarterly reporting requirements for at least the first two quarters of this year.

Why would Congress and the CFTC not want to consider all of the economic research on this subject that has already been done? If we don't want the regulators to consider economic analyses before adopting rules, what is the point of FSOC and of Form PF and of all the information that the regulators now require? When Congress mandates that hundreds of millions of dollars be spent collecting financial information, and then regulators argue that rules should be adopted without even considering…

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…