Scott O'Malia, a member of the Commodity Futures Trading Commission, said the agency should take a different approach to cross-border rules mandated by the Dodd-Frank Act. "First, the entire guidance should be scrapped and the document should be redrafted as a formal rule making that provides an opportunity for public comment and includes a cost-benefit assessment," O'Malia said. "Second, the proposal should provide a clear, consistent interpretation of the 'direct and significant' connection with a sufficient rationale for the extent of the commission's extraterritorial reach."

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