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...I respectfully dissent on In re TOTSA TotalEnergies Trading SA because of the lack of evidence to support the alleged charges and the consequences of asserting that legitimate commercial hedging activity is illegal. Over the past several years, the pocketbooks of Americans and consumers all over the world have been hit hard by inflation and policies that have resulted in higher gas prices and…
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...I respectfully dissent on In re Cowen and Co. because the administrative record does not include evidence that any CFTC registered Associated Persons (APs)[1] engaged in activity that was in violation of the CFTC’s recordkeeping requirements for introducing brokers (IBs), such as maintaining records of transactions, orders, and other business “relating to dealing in commodity…
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