"H.R. 238 contains prudent internal risk controls to safeguard market data and improved customer protections sought by the market participants who rely on derivatives to manage their risks," Lukken wrote. "These are examples of policy enhancements that have garnered tremendous favor in recent years as evidenced by the bi-partisan support they have received in previous Congressional sessions."
Lukken also praised two valuable amendments to H.R. 238; one regarding access to source code under the CFTC's proposed rules to regulate automated trading and another that addresses Ownership and Control Reporting (OCR)."In particular, FIA would like to lend our support to the bi-partisan Duffy/Scott amendment protecting critical intellectual property that is key to the innovative culture in the United States. Additionally, we commend Congresswoman Hartzler for her amendment recognizing the need to improve the quality of information submitted for the Commission’s surveillance and large trader reporting programs."