Aug. 13, 2023
This ruling is a great step forward in protecting against fraud and manipulations for all parties involved. The re-clarification of what a transaction is, is a great start because we should know more than just the execution of it. Anyone who may have any opposition to this ruling should re-visit the safe harboring provisions involved because those are more than fair, and most importantly this is in-line with rule 180.2 that the CFTC has. Encouraging portfolio compression would also streamline a lot of confusion when it comes to how counterparties handle derivative contracts and reduce the gray area where fraud might lie. Overall a great proposal.