Review of the Commitments of Traders Reporting Program - Request for Comment

The American Cotton Shippers Association (ACSA) supports the Commission's review of the Commitments of Traders (COT) report, advocating for increased publication frequency, greater granularity, and modernized reporting methodologies to enhance transparency. They emphasize that these improvements should be balanced with maintaining the accuracy of the data and protecting the anonymity of individual market participants.

The National Pork Producers Council supports the modernization of the Commitments of Traders (COT) reporting program, provided it enhances usefulness for commercial end users and maintains data integrity. They emphasize the importance of preserving historical continuity, ensuring timely reporting without compromising confidentiality, and maintaining the ability to distinguish risk management from investment activity.

The Futures Industry Association (FIA) supports the modernization of the Commitments of Traders (COT) reporting program but recommends a phased implementation to ensure data accuracy. They specifically propose subdividing the "other reportables" category, increasing the timeliness and frequency of reports, and coordinating these changes with the upcoming Part 17 large trader reporting compliance date.

The commenter proposes that the Commission increase the frequency of Commitments of Traders (COT) Reports to a daily or bi-weekly schedule to improve market transparency and price discovery. They also suggest expanding the scope of the reports to include a broader range of contracts, such as event contracts, to better reflect modern market complexities.

The North American Export Grain Association (NAEGA), a trade association representing agricultural commodity exporters, supports the CFTC's review of the Commitments of Traders (COT) Reporting Program. They advocate for increasing the frequency and timeliness of COT reports to better reflect fast-moving markets, while emphasizing the need to maintain data integrity, confidentiality, and accuracy.

The Managed Funds Association (MFA) supports the CFTC's ongoing review of the Commitments of Traders (COT) Reports but urges a cautious, evidence-based approach to any changes. They recommend maintaining the current weekly publication schedule and data validation processes to protect trader confidentiality and data integrity, while suggesting specific improvements to data disaggregation and minimum reporting thresholds.

Amcot, an association of cotton marketing cooperatives, submits this comment to express support for the views previously shared by the National Cotton Council. The organization does not provide specific arguments of its own but urges the Commission to consider the National Cotton Council's feedback regarding the Commitments of Traders Reporting Program.

Optiver, a global market-making firm, supports the modernization of the Commitments of Traders (COT) Reporting Program to increase the frequency of data publication. They recommend a targeted pilot program for daily or intraday reporting in liquid markets to provide more timely and operationally useful information for active market participants.

The commenter is requesting that the data be released more frequently, specifically suggesting a daily or weekly update rather than the current schedule. They argue that modern technology should allow for more timely data to better reflect current market conditions.