Comment on CFTC-2026-1453, CFTC-2026-1453-0001, Brubaker Public Relations, Inc.

Summary: Steven G. Brubaker, representing Brubaker Public Relations, Inc., supports the proposed data reporting framework but argues that the current end-of-day threshold creates an "investigatory-predicate gap." He advocates for adding an intraday volume trigger to ensure that high-volume market makers and other significant traders are captured by the Commission's surveillance and investigatory functions.