Date: June 24, 2016
To: Christopher Kirpatrick, Secretary of the Commission, CFTC
Filing Type: Regulatory
Description: The Chamber and undersigned organizations appreciate the CFTC’s need for timely access to data in order to fulfill its market surveillance mission, the proprietary source code requirements of Regulation AT are a bridge too far. By mandating on demand access to proprietary source code and the development of source code repositories, the CFTC not only compromises established due process rights—it also adopts policy in direct contradiction to other agencies of the U.S. government and increases the risk of cyberattack, all while not providing any tangible benefit to the CFTC. Consequently, we believe that the proprietary source code provisions of Regulation AT should be eliminated in their entirety.