Comment on CFTC-2026-1453, CFTC-2026-1453-0001, Conan, Mak

Summary: The organization APES, representing global retail market participants, supports the CFTC's proposed revisions to data reporting for fully collateralized event contracts. They argue that the new framework is necessary to address systemic accounting vulnerabilities, "synthetic wrappers," and the lack of transparent audit trails in shadow banking and derivatives markets.