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.

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.

Better Markets, a non-profit organization, supports the continued publication of the CFTC’s Commitments of Traders (COT) Reports and argues that the Commission should increase their publication frequency. They contend that more frequent reports would provide market participants with more timely data and better insights into market trends without compromising participant anonymity.

The National Feed Association and the National Cooperative Growers Association are supporting the review of the Commitments of Traders (COT) Reporting Program. They advocate for more timely, granular, and interpretable data to help market participants better understand supply dynamics and manage risk.