In February 2017, CFTC Chairman J. Christopher Giancarlo announced Project KISS – for “Keep it Simple, Stupid” – an initiative designed to simplify and reduce the cost of CFTC rules, regulations and practices. To facilitate this process, the CFTC requested and reviewed public comments on regulatory reform. See “New CFTC Chair Outlines Enforcement Priorities and Approaches to FinTech, Cybersecurity and Swaps Reform
” (Nov. 9, 2017). The CFTC recently announced the first tangible product of Project KISS: proposed amendments to regulations that would codify existing CFTC staff advisory and no-action letter relief for commodity pool operators and commodity trading advisors. This article summarizes the key proposals, with commentary from experienced lawyers, including a former CFTC attorney. For coverage of additional initiatives by the CFTC, see “Settlements With Three Major Banks and Five Individual Enforcement Actions Follow CFTC Anti-Spoofing Initiative
” (Feb. 15, 2018); and “Newly Revealed CFTC Self-Reporting and Cooperation Regime Could Offer Benefits to Fund Managers, or Lead to Increased Enforcement
” (Oct. 19, 2017).
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