External Meetings: Telephone Call with AFR

Representatives for AFR called CFTC staff to discuss the views expressed in AFR’s Feb. 22 commenter letter to the CFTC and Aug. 29 comment letter to the SEC and CFTC.  The AFR representative expressed his view that the Business Conduct Standards under the CFTC and SEC’s respective jurisdictions regulate different types of markets that may have different types of market participants, including certain Special Entities. The AFR representative expressed his view that those differences may justify the CFTC adopting Business Conduct Standards rules that are different from the SEC.