MMI Comment Letter to the CFTC Regarding Supplemental Notice of Proposed Rulemaking for Regulation AT

This Proposed Rule threatens to erode confidence in our country’s resolve to uphold the regulatory standards that protect the innovation that drives much of our economy. Despite the changes in the proposed rule as listed in the Supplemental, it still grants a government agency the ability to bypass due process to access confidential and highly sensitive trade secrets protected by intellectual property rights. As such, this provision should not be included in the final rule and the subpoena process should remain.