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April 2, 2024

CFTC Must Make Swap Dealers and FCMs More Resilient to Cyber Threats

WASHINGTON, D.C.— Cantrell Dumas, Director of Derivatives Policy, issued the following statement in connection with the filing of a comment letter to the Commodity Futures Trading Commission (CFTC) in response to a proposed rule requiring futures commission merchants (FCMs), swap dealers, and major swap participants to establish, document, implement, and maintain an Operational Resilience Framework (ORF):

“The recent surge in cyberattacks, with significant breaches like those at AT&T and ION Group, has laid bare the vulnerabilities in our financial sector and led to massive financial losses. These incidents drive home the point that robust cybersecurity isn’t just a necessity; it’s critical for the stability and integrity of our markets. The CFTC’s proposed rule provides an operational resilience framework for swap dealers and FCMs that takes steps towards making a more resilient environment that can swiftly adapt and respond to threats.

“The proposed rule leverages insights from past global economic events like Brexit, the LIBOR transition, and the COVID-19 pandemic, providing valuable lessons. Nevertheless, the CFTC’s leaning towards substituted compliance raises concerns. It’s problematic for foreign entities to meet U.S. standards through substituted compliance, particularly in vital areas like cybersecurity. Therefore, we must prevent foreign firms from selecting weaker laws under the guise of compliance with U.S. standards, especially concerning critical matters like operational resilience. To truly protect our financial markets, we must ensure that all firms, domestic and international, adhere to the highest standards of operational and cybersecurity resilience.”

You can find our comment letter here.


Better Markets is a non-profit, non-partisan, and independent organization founded in the wake of the 2008 financial crisis to promote the public interest in the financial markets, support the financial reform of Wall Street and make our financial system work for all Americans again. Better Markets works with allies—including many in finance—to promote pro-market, pro-business and pro-growth policies that help build a stronger, safer financial system that protects and promotes Americans’ jobs, savings, retirements and more. To learn more, visit

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