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Better Markets Issues Comment Letter on the CFTC's Bankruptcy Regulations Proposal

The CFTC is proposing the first comprehensive review and update of the bankruptcy framework for futures commission merchants and derivatives clearing organizations in nearly 40 years. The current framework is simply not suited for current market practices, which have evolved considerably since the last comprehensive review. It is therefore of the utmost importance that the framework be updated to reflect these changes before a major bankruptcy occurs. Failure to do so could result in significant harm to market participants.