Anonymous comment on CFTC-2026-0859, CFTC-2026-0859-0001

This comment respectfully proposes two modifications to the Commitments of Traders Reports (“COT Reports”). First, the policies underlying the COT Reports would be better served by more frequent publication. Specifically, a daily or, at minimum, a bi-weekly publication schedule, would promote several important goals: -Market Transparency. The COT Reports have long served as an important source of market transparency by providing information about aggregate trader positioning in futures and options markets. The structure of modern markets, however, has changed since the COT program began. Today, electronic trading occurs in milliseconds, algorithmic trading systems continuously analyze market data, and exchanges collect and process transaction data on a near real-time basis. A daily or bi-weekly reporting schedule would provide a more current view of market conditions and would better align the availability of public information with the speed at which modern markets operate. -Price Discovery. More frequent publication would also improve price discovery. Futures markets function most efficiently when prices reflect the broadest possible set of information. By reducing the lag between the collection of position data and publication, the Commission would allow market participants to more efficiently incorporate information into their analyses. -Reducing Informational Asymmetry. Large market participants often possess superior resources and access to proprietary data that may enable them to infer positioning trends before smaller market participants. Retail investors, academics, journalists, and smaller firms frequently rely on publicly available COT data as one of the few sources of market positioning information. More frequent publication would narrow the information gap between market participants, promoting fairer and more competitive markets. -Regulatory Benefits. Additional data points would improve the ability of regulators, researchers, and market observers to detect unusual trading patterns, potential market manipulation, excessive concentration, and other misconduct. Greater reporting frequency would create a better dataset for surveillance and analysis, enabling both the Commission and the public to identify developments that may warrant investigation. Second, the Commission should consider expanding the number of contracts included in the COT Reports. Since the COT reporting framework was established, the futures and derivatives markets have grown significantly in both size and complexity, with substantial trading activity now occurring in products that are not separately reported, for example event contracts. Expanding coverage to include additional contracts would provide market participants, researchers, and regulators with a more comprehensive view of markets and risk across the derivatives landscape. As with more frequent publication, greater contract coverage would enhance transparency and price discovery, reduce informational asymmetries, and provide more complete data for market surveillance and academic analysis. Advances in data collection and reporting technology make it increasingly feasible to publish information on a broader range of contracts, and doing so would ensure that the COT Reports continue to reflect the realities of modern markets and remain a valuable public resource.