Comment on CFTC-2026-1388, CFTC-2026-1388-0001, Veerpoint Capital LLC

Veerpoint Capital LLCOpposeBusiness
Summary: A Commodity Trading Advisor (CTA) opposes the proposal to move to 24/7 trading markets, arguing that it creates untenable risk management burdens for small firms. The commenter contends that the move primarily benefits exchanges through increased commissions while causing liquidity reductions and higher costs for clients.
Hello, I am writing regarding the proposal of markets that will trade 24/7 Although there are likely many statistical and evidenced-based reasons to reject markets that trade 24/7, I want to hone in one 1 specific that is touched on in bullet 1A5 but I want to expand on further. (5. How would institutional investors need to adapt to manage weekend price formation when existing risk management, governance, compliance and oversight frameworks may assume that significant weekend events result in opening price gaps rather than continuous benchmark price movements capable of triggering contractual, regulatory, investment, or risk management provisions? What would be the expected cost of this adaptation, if any?) My Comment: As a Commodity Trading Advisor registered with the NFA (NFA ID: 0568492), I have been dreading the day that we move to 24/7 trading. It is my belief that this is a slippery slope - starting with just a couple of markets that will evolve into many more markets as it only serves to generate more commissions by the exchanges. My biggest worry is that it is untenable for firms like my own to manage this kind of risk over the weekend - I have a life outside of work that I would like to enjoy, especially on the weekends. As a result, I would need to either stop trading altogether or exit positions going into the weekend and reopen them to start the next week. The former will be a reduction in liquidity across markets as well as a major disruption to my livelihood, and the latter will balloon the commissions that my clients are forced to pay. If I could pose a question back to the commission, it would be: "Who, aside from the exchanges which benefit from increased commissions, is asking for this?" - it only poses added complexity for the industry and tries to fix something that is not broken

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