At my confirmation hearing for this role, I testified, “If confirmed, my highest priority would be to work to ensure that the markets are working well—that they are open, fair, and competitive….Whether focused on hard commodities like agriculture, energy, or metals, or on the financial sector, the Commission plays a critical role in ensuring that these markets work well.  That starts with the Agricultural sector—the farmers, ranchers, and producers our nation depends on—to put food on our tables and contribute to our nation’s economic activity.  For our farmers and ranchers to help drive our economy and feed the world, they need U.S. derivatives markets for risk management and price discovery.” [1]

Transparency is critical to fair and orderly markets.  It provides the market confidence that pricing is appropriate, reflects market fundaments, and is free of manipulation and excessive speculation.  This confidence is reflected in the fact that the Commission’s Commitments of Traders report that reports position information for the largest traders in our markets is consistently the most downloaded item from our website.  Market participants, news media, researchers, academics, and industry professionals, use these reports to determine current trends, conduct analysis of trading patterns, and inform market strategies.  The importance of these reports was highlighted when the Commission had to postpone the reports temporarily after the cyber attack on Ion Markets. [2]

Fair and orderly markets also require confidence that the Commission is monitoring markets and taking strong action to promote market integrity.  The Commitments of Traders report is a tool in the Commission’s market surveillance program and enforcement program to deter and catch market manipulation and excessive speculation.  As I have visited with our nation’s farmers and producers, I have heard about their need for the Commission to protect the integrity of our markets, to ensure that prices are not artificially increased, thereby unfairly raising input costs.

The Commission has a critical mission to deter and combat excess speculation in our markets—which I discussed Monday in a recent enforcement action. [3]In September, I proposed that the CFTC use its expertise and data to study whether prices in key commodities markets are being determined by market fundamentals, and to root out any manipulation and excessive speculation so that families and businesses aren’t forced to pay artificially increased prices. [4] These deep dive studies would need data on the activity of the largest traders in our markets—which is the sole focus of these reporting requirements.

The Commission will benefit from strengthening and modernizing this important surveillance tool, as will the public. I particularly appreciate the recognition of the need to determine positions across markets for more comprehensive data, and for data quality improvements. The proposed changes would enhance the Commission’s ability to identify disruptive or manipulative trading activity. For these reasons, I support the proposed rule. I thank the staff and look forward to public comment.

[1] Statement of Christy Goldsmith Romero, Confirmation Hearing, U.S. Senate Committee on Agriculture, Nutrition, and Forestry (Mar. 2, 2022) Testimony_Goldsmith Romero.pdf (senate.gov).

[2] See CFTC Announces Postponement of Commitment of Traders Report, (Feb. 16, 2023) CFTC Announces Postponement of Commitments of Traders Report | CFTC.

[3] See CFTC Commissioner Christy Goldsmith Romero,The Importance of Protecting Commodity Markets Against Excess Speculation in the Ghost Cattle Fraud Case, (June 5, 2023) Statement of Commissioner Goldsmith Romero on the Importance of Protecting Commodity Markets Against Excessive Speculation in the Ghost Cattle Fraud Case CFTC v. Cody Easterday | CFTC.

[4] See Opening Statement of Commissioner Christy Goldsmith Romero Before the Energy and Environmental Markets Advisory Committee, Opening Statement of Commissioner Christy Goldsmith Romero Before the Energy and Environmental Markets Advisory Committee | CFTC (September 20, 2022).