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The Commodity Exchange Act TESTIMONY of ROBERT G Senate Agriculture Committee: The Commodity Exchange Act TESTIMONY OF ROBERT G. EASTON ON BEHALF OF THE MANAGED FUTURES ASSOCIATION BEFORE THE COMMITTEE ON AGRICULTURE, NUTRITION, AND FORESTRY UNITED STATES SENATE Mr. Chairman and members of the Committee: My name is Robert G. Easton and I am the Chairman and Chief Executive Officer of Commodities Corporation Limited located in Princeton, N.J. I also am Chairman of the Government Relations Committee of the Managed Futures Association ("MFA"). I appreciate the opportunity to testify on behalf of MFA at this hearing on the Commodity Exchange Act. MFA, a not-for-profit national trade association with over 600 members, represents the managed futures industry. The objective of the MFA is to enhance the image and understanding of the industry, to further constructive dialogue with regulators in pursuit of regulatory reform, and to improve communication with, and training of, the Association's members through effective conferences and communication programs. MFA is governed by an elected board of directors and has offices in Washington, D.C. and California. MFA membership is composed primarily of commodity pool operators and commodity trading advisors who are responsible for the discretionary management of the vast majority of the estimated $20 billion currently invested in managed futures products, including commodity pools and managed futures accounts. Commodities Corporation Limited is an MFA member and is registered as both a commodity pool operator and a commodity trading advisor, managing client capital and its parent company's proprietary capital since 1969. Currently, our company has over $1.3 billion under management. The business operations of MFA members are subject to regulation under the Commodity Exchange Act (the "Act") by the Commodity Futures Trading Commission ("CFTC") and, pursuant to delegation of certain regulatory functions under the Act, by the industry's self regulatory organization, the National Futures Association ("NFA"). The Act regulates the business activities of commodity pool operators and commodity trading advisors through registration, disclosure, record keeping and reporting requirements. As managers of funds provided by their clients, MFA's members act as purchasers of futures industry services and thus are the indirect beneficiaries of market protection rules under the Act. Thus, those sections of the Act and those activities of the CFTC that regulate the functioning of, or participation in, the markets have an important impact on commodity pool operators and commodity trading advisors as representatives of their clients. Regulation of the markets by the CFTC for the protection of market users is not, however, the only regulation affecting managed futures professionals. The CFTC's regulations contain entirely separate regulatory regimes for commodity pool operators and commodity trading advisors. Unlike most other members of the futures industry, however, managed futures professionals are confronted with a multiplicity of other regulations, frequently developed with other purposes in mind, but which impact their investment management function. Efficiency and competition in these markets are adversely affected by this multiplicity of regulation. Due to the potential for duplicative and contradictory regulation of these entities by the Investment Company Act of 1940 and the Investment Advisers Act of 1940, MFA has sought to provide a clear exclusion for these registrants in legislation now under consideration by the Senate Banking Committee. In the interest of outlining our position on those matters we consider currently to be of primary importance, we respectfully request that our letter of August 28, 1995 responding to the request from the Chairman of this Committee for our views be included as part of the record. A. Regulation under the Act. The Act was originally drafted to protect market participants, largely retail speculative accounts or those who hedged their risks in the markets. Increasingly over the past twenty years, both the number and type of participants in the futures markets have changed dramatically. Increasingly, market participants are institutional or commercial users, and retail investors who access the markets through professionally managed funds and accounts. The trend toward investment in managed funds by retail investors to access futures and related markets has been welcomed by industry observers and the regulators because of the presence of professional management and limited liability. There are a number of significant benefits investors realize through professional management of their capital. Due to the nature of these markets, which move quickly on an intraday basis and, at times, are volatile, it is difficult to successfully trade over the long term absent total devotion to trading. Few investors are able individually to commit the time and resources necessary to achieve consistent success in trading these markets. Professional management generally provides an investor with seasoned market experience, more consistency in trading approach, administrative convenience and disclosure of the nature and manner in which the investor will have market exposure. In addition, in managed funds, investors generally are able to achieve significantly greater market and trading strategy diversification than they could achieve by investing separately, which tends to increase the consistency and decrease the volatility of their investment returns and provides the potential to significantly enhance total portfolio returns. Through managed funds investments, investors frequently are able to access far more successful managers who otherwise would not trade the relatively small amount being invested by a single investor. Such funds frequently reflect returns which are not correlated with traditional asset classes and, therefore, provide diversification to stock and bond portfolios. Successful fund managers provide an investment approach based on rigorous research and analysis, strict adherence to investment discipline and diversification to minimize risk. Established risk management techniques frequently reduce actual risk exposure to significantly less than an investor's total investments, but fund structures generally ensure loss exposure does not exceed an investor's total investment plus profits. By providing significant liquidity to the futures markets, commodity funds also enable institutions, corporations, pension plans, farmers and others to hedge effectively against their market risks. Managed futures also confer benefits on the U.S. economy by employing countless persons at futures exchanges and brokerage houses and as accountants, lawyers and other services providers. B. Recognition of Sophisticated Market Participants. MFA members and the products they offer are more stringently regulated than any other product in the world. The CFTC, in administering the Act, oversees and monitors the business activities of commodity pool operators and commodity trading advisors through registration, disclosure, record keeping and reporting requirements and regulates the activities of the commodity brokers through which these funds place their trades as well as the activities of the commodity exchanges on which these transactions are executed. The National Futures Association, the self-regulatory body of the industry, also regulates the sales, promotional and operational activities of all these entities. Each of the exchanges on which these contracts trade also regulates the activities of those trading on their markets. In addition, the offer and sale of interests in commodity funds are subject to both the Securities Act of 1993, requiring registration of interests sold publicly and mandating disclosure requirements, and the Securities Exchange Act of 1934, as well as each of the 51 states' securities laws. The Act, as originally structured, imposes restraints on investment freedom, costs and inefficiencies that provide no corresponding benefit for institutional, professionally managed or sophisticated market participants. These participants have neither the desire nor need for this type of protection. This Committee previously has recognized the need for this type of flexibility as evidenced by the exemptive authority granted to the CFTC under the Futures Trading Practices Act of 1992 and its instruction to exempt appropriate persons with respect to certain market transactions. MFA recommends that additional consideration be given by the CFTC and other regulators to the elaboration of a two-tiered regulatory structure, such as that utilized significantly in other countries with sophisticated financial markets. Such a structure is premised on the recognition that there are two classes of investors with markedly different needs for regulatory protection. A two-tiered regulatory structure will provide a significantly simpler framework for the regulation of those transactions that are entered into among institutional, professional or otherwise- regulated market participants, as distinguished from the general investing public, for which a higher standard of regulation and disclosure would be required. Attention should be paid particularly to exempting transactions in appropriate markets among appropriate participants who are able to protect themselves through their sophistication and experience. Some steps have been taken since 1992 which provide a model for future initiatives of the same type. For example, the adoption of Rule 4.7 in 1992
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