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.

Steven G. Brubaker, representing Brubaker Public Relations, Inc., opposes the Commission's proposal to replace the standard derivatives reporting framework with a standalone regime for event contracts. He argues that the Commission has failed to provide a reasoned explanation or evidence that the new framework preserves the same level of regulatory transparency and oversight as the existing general framework.

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.

Steven G. Brubaker, representing Brubaker Public Relations, Inc., supports the proposed modernization of the transaction-reporting framework for Covered Event Contracts but argues that the current proposal fails to capture critical relational data. He recommends adding specific data elements regarding contract originators, market maker status, and affiliate relationships to improve the Commission's market surveillance capabilities.