Blog FinReg + Policy Watch October 03, 2022

CFTC Commissioner Romero Calls on Agency to Bring the “HEAT” in Enforcement Actions

Our recent client alert discusses the CFTC’s longstanding practice of settling enforcement cases without seeking admissions of wrongdoing (so-called “no-admit/no-deny” settlements). CFTC Commissioner Romero suggests application of a “HEAT” test (Heightened Enforcement Accountability and Transparency), which would encourage CFTC staff to push for admissions of wrongdoing in actions with one or more bad factors.

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