In February 2025, the CFTC Division of Enforcement issued an Enforcement Advisory with guidance to CFTC enforcement staff on evaluating credit for self-reporting, cooperation and remediation when recommending penalties in enforcement matters. On May 21, 2025, then-CFTC Commissioner Christy Goldsmith Romero issued a statement discussing her own process for evaluating cases and cooperation credit and calling on the CFTC to provide more transparency and detail in its public documents regarding its decisions on charging both monetary and nonmonetary sanctions in enforcement matters. Such additional transparency would make incentives for self-reporting, remediation and cooperation much clearer, she argued. This article parses Romero’s statement, which raises legitimate issues the current Commission should still consider notwithstanding her departure. See “CFTC Advisory on Self-Reporting, Cooperation and Remediation Overhauls Years of Guidance” (Mar. 27, 2025).