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38–703 PDF 2007

S. HRG. 110–183

NOMINATIONS HEARING:

JILL E. SOMMERS, OF KANSAS,

AND BARTHOLOMEW H. CHILTON OF

DELAWARE TO BE COMMISSIONERS OF

THE COMMODITY FUTURES TRADING COMMISSION

HEARING

BEFORE THE

COMMITTEE ON AGRICULTURE, 

NUTRITION, AND FORESTRY

UNITED STATES SENATE

ONE HUNDRED TENTH CONGRESS

FIRST SESSION

JUNE 27, 2007

Printed for the use of the 

Committee on Agriculture, Nutrition, and Forestry

(

Available via the World Wide Web: http://www.agriculture.senate.gov 

COMMITTEE ON AGRICULTURE, NUTRITION, AND FORESTRY

TOM HARKIN, Iowa, Chairman 

PATRICK J. LEAHY, Vermont 

KENT CONRAD, North Dakota 

MAX BAUCUS, Montana 

BLANCHE L. LINCOLN, Arkansas 

DEBBIE A. STABENOW, Michigan 

E. BENJAMIN NELSON, Nebraska 

KEN SALAZAR, Colorado 

SHERROD BROWN, Ohio 

ROBERT P. CASEY, Jr., Pennsylvania 

AMY KLOBUCHAR, Minnesota 

SAXBY CHAMBLISS, Georgia 

RICHARD G. LUGAR, Indiana 

THAD COCHRAN, Mississippi 

MITCH MCCONNELL, Kentucky 

PAT ROBERTS, Kansas 

LINDSEY GRAHAM, South Carolina 

NORM COLEMAN, Minnesota 

MICHEAL D. CRAPO, Idaho 

JOHN THUNE, South Dakota 

CHARLES E. GRASSLEY, Iowa

MARK HALVERSON, Majority Staff Director 

JESSICA L. WILLIAMS, Chief Clerk 

MARTHA SCOTT POINDEXTER, Minority Staff Director 

VERNIE HUBERT, Minority General Counsel 

(II) 

(III)

C O N T E N T S 

Page

HEARING(S):

Nominations Hearing: Jill E. Sommers, of Kansas, and Bartholomew H. 

Chilton of Delaware to be Commissioners of the Commodity Futures Trading Commission .................................................................................................... 1

Wednesday, June 27, 2007

STATEMENTS PRESENTED BY SENATORS 

Harkin, Hon. Tom, a U.S. Senator from Iowa, Chairman, Committee on 

Agriculture, Nutrition, and Forestry .................................................................. 1

Chambliss, Hon. Saxby, a U.S. Senator from Georgia ......................................... 2

Panel I 

Chilton, Bartholomew H., of Delaware, to be a Commissioner of the Commodity Futures Trading Commission ................................................................. 6

Sommers, Jill E., of Kansas, to be a Commissioner of the Commodity Futures 

Trading Commission ............................................................................................ 4

APPENDIX 

PREPARED STATEMENTS: 

Chilton, Bartholomew H. ................................................................................. 20

Sommers, Jill E. ............................................................................................... 22

DOCUMENT(S) SUBMITTED FOR THE RECORD: 

Committee questionnaire and Office of Government Ethics Executive 

Branch Personnel Public Financial Disclosure Report filed by Bartholomew H. Chilton ..................................................................................... 26

Committee questionnaire and Office of Government Ethics Executive 

Branch Personnel Public Financial Disclosure Report filed by Jill E. 

Sommers ........................................................................................................ 46

QUESTION(S) AND ANSWER(S): 

Chilton, Bartholomew H.: 

Written response to questions from Hon. Tom Harkin ................................. 62

Sommers, Jill E.: 

Written response to questions from Hon. Tom Harkin ................................. 64

(1)

NOMINATIONS HEARING: 

JILL E. SOMMERS, OF KANSAS, 

AND BARTHOLOMEW H. CHILTON OF 

DELAWARE TO BE COMMISSIONERS OF 

THE COMMODITY FUTURES TRADING 

COMMISSION 

Wednesday June 27, 2007

UNITED STATES SENATE, COMMITTEE ON AGRICULTURE, NUTRITION, AND FORESTRY, Washington, DC 

The Committee met, pursuant to notice, at 2:06 p.m., in Room 

SR–328a, Russell Senate Office Building, Hon. Tom Harkin, Chairman of the Committee, presiding. 

Present or submitting a statement: Senators Harkin, Chambliss, 

Lugar, Roberts, Coleman, and Thune. 

STATEMENT OF HON. TOM HARKIN, A U.S. SENATOR FROM 

IOWA, CHAIRMAN, COMMITTEE ON AGRICULTURE, NUTRITION, AND FORESTRY 

Chairman HARKIN. The Senate Agriculture Committee will come 

to order. 

This afternoon I am pleased to welcome to our Committee this 

afternoon two nominees to the Commodity Futures Trading Commission. Jill Sommers is nominated for the remainder of the term 

expiring April 13th, 2009, and I will defer to Senator Roberts for 

the purpose of an introduction. 

Bart Chilton is nominated for the remainder of the term expiring 

April 13th, 2008. Both of these nominees have had extensive experience here on the hill. As I said, I will defer to Senator Roberts 

on Ms. Sommers. I will say Mr. Chilton has most recently worked 

for Senator Tom Daschle, who was a very valuable member of this 

Committee. Mr. Chilton also served in important positions at the 

Department of Agriculture, the Farm Credit Administration, and 

the National Farmers Union. 

The Commodity Futures Trading Commission has critical regulatory responsibility to protect and ensure the integrity and fairness and transparency of our Nation’s futures options and derivatives markets. These markets are highly competitive, they are innovative and rapidly changing. They are vital to the functioning of 

our economy, yet it is likewise vital that they are properly regulated. 

2

The CFTC has a critical responsibility to protect customers, market integrity and the public while also promoting efficient and 

internationally competitive futures and derivatives markets. With 

good reason there has been a great deal of interest in restoring 

fuller CFTC authority to monitor and take appropriate regulatory 

action in energy derivatives markets, as well as in urging CFTC to 

utilize its existing authority to the maximum extent. 

I do give the CFTC credit for filing energy-related complaints 

against more than 50 firms and collecting some $300 million in 

penalties in recent years. However, it is essential that the CFTC 

erase any doubts about its aggressiveness in pursuing energy-related violations and that Congress restore to CFTC the authority 

that it needs over energy derivatives markets. 

So I look forward to hearing the nominee’s statements and answers to our questions. 

I will now turn to Senator Chambliss for an opening statement. 

STATEMENT OF HON. SAXBY CHAMBLISS, A U.S. SENATOR 

FROM GEORGIA 

Senator CHAMBLISS. Thank you very much, Mr. Chairman, and 

I applaud you for holding this very important confirmation hearing 

today. 

Currently the Commodity Futures Trading Commission is severely hampered by vacancies on the Commission. This Committee 

is tasked with filling these positions to ensure that the Commission 

is able to function appropriately. 

Just last week Reuben Jeffrey was confirmed to be Under Secretary of state. His departure from the CFTC, where he was serving as Chairman, leaves the Commission to operate with only two 

sitting Commissioners. 

Let me say, Mr. Chairman, I have only been in the Senate for 

four years, the House for eight years before that. But Reuben Jeffrey really did an outstanding job. He committed himself to really 

learning the industry and making sure that from a regulatory 

standpoint the futures trading industry did what it was supposed 

to do. He will be missed, but we certainly look forward to filling 

that vacancy, as well as the other one. 

While both Commissioner Walt Lukken and Mike Dunn are quite 

capable, the Commission is designed to operate as a five person. 

And moving forward the pending nominations before the Committee today is imperative to ensure functionality of the CFTC. 

The two nominees before us today are certain no strangers to the 

United States Senate. Jill Sommers spent over four of her career 

years serving Senate Majority Leader Bob Dole in various capacities and Bart Chilton was a senior advisor to Senate Majority 

Leader Tom Daschle. Both these nominees bring varied skills to 

the job that will complement those of Commissioners Lukken and 

Dunn. 

I have known Jill for many years and I believe that her experience both in Government and within the industry will be very valuable to the CFTC operation. 

Mr. Chilton spent much of his career working on behalf of our 

farmers and ranchers and I believe this experience will enable him 

3

to bring an important producer perspective to the regulation of agriculture commodities traded on futures markets. 

The Commission will be well served if both of these nominees are 

confirmed by the Senate. 

Again, Mr. Chairman, thank you for holding this hearing. I am 

hopeful these nominations will move through the Committee and 

the full Senate in an expeditious manner. 

Chairman HARKIN. Thank you very much, Senator Chambliss. 

Now I have two housekeeping things and then I will yield to Senator Roberts for introduction. That is why did I did not go on about 

you, Ms. Sommers, because I was going to yield to him on that. 

But two housekeeping things that we do for all nominees, would 

both of you please raise your right hand. 

Do you swear that the testimony you are about to present is the 

truth, the whole truth, and nothing but the truth? 

Ms. SOMMERS. I do. 

Mr. CHILTON. I do. 

Chairman HARKIN. Secondly, do you agree that if confirmed, you 

will appear before any duly constituted committee of Congress, if 

asked? 

Ms. SOMMERS. Yes, sir. 

Mr. CHILTON. Yes. 

Chairman HARKIN. Thank you very much. 

Now I would yield to the distinguished Senator from Kansas for 

the purposes of an introduction. 

Senator ROBERTS. Mr. Chairman, thank you very much. It is an 

honor and a privilege to introduce to you someone who has already 

been introduced by my good friend, Saxby Chambliss. I want to associate myself with his remarks. With only two people on the CFTC 

and a five-member CFTC, these appointments are very, very crucial and I hope we can expedite this just as soon as possible. 

It is a privilege to introduce and convey my strongest possible 

support for the nomination of Jill Sommers to the CFTC. As has 

been said, she is a native Kansan. She is a graduate of a school 

that I think is not too far from Manhattan, Kansas and Kansas 

State University. I think they call it the University of Kansas, a 

very proud graduate, I might add. 

I understand her parents, John and Joyce, are here from Fort 

Scott, Kansas. If they could raise their hand, that would be appreciated. 

Fort Scott is a great, great community, Mr. Chairman, has a very 

rich history in Kansas. We call it a real gem in Kansas. So she has 

had a proud heritage and growing up in small-town America but 

a great small town. 

She is very well qualified for this position, having served on the 

staff of Senator Bob Dole, as anybody in public service in Kansas 

has served on the staff of Bob Dole from one time or another, 

whether or not we were on the staff or not. As a matter of fact, 

I am still a staff member for Bob Dole, but then that is another 

whole story. 

At any rate, she has worked in several positions in the futures 

industry so she has the background and the understanding necessary to address the very difficult issues she will face as a commissioner. 

4

More importantly, being from Kansas, she truly understands agriculture and the significant role that the CFTC plays in regulating 

our agriculture markets. I am convinced she is more than up to the 

task. I am very proud to support her nomination as a fellow Kansan. 

And I thank you, Mr. Chairman, for the privilege. 

Chairman HARKIN. Thank you very much, Senator Roberts. 

Now we will turn first to Ms. Sommers and then second to Mr. 

Chilton. Your statements will be made a part of the record in their 

entirety and if you could summarize those in several minutes, I 

would appreciate it very much. 

Ms. Sommers, welcome, and welcome your family members here 

and your husband, also. Mike. You did not introduce him. I will introduce him. Her husband, Mike, is here too. 

Ms. Sommers, please go ahead. 

STATEMENT OF JILL E. SOMMERS, OF KANSAS, TO BE A COMMISSIONER OF THE COMMODITY FUTURES TRADING COMMISSION 

Ms. SOMMERS. Thank you, Chairman Harkin. And certainly 

thank you to Senator Chambliss and Senator Roberts for those 

kind words, and members of the Agriculture Committee. 

I am honored to sit before you today as a nominee to be a Commissioner at the Commodity Futures Trading Commission. It is a 

true honor and privilege for me to be nominated by the President 

for this distinguished position. 

I would like to thank my husband, Mike, who is here, and my 

parents, who are here with me today. We have three small children 

who we decided not to bring with us this morning to a Senate hearing. 

I started working on Capitol Hill more than 15 years ago for Senator Bob Dole as an intern from the University of Kansas. And I 

worked for him in various capacities for almost five years. From 

Senator Dole I learned the importance of a fair and reasonable decision-making process. 

I grew up in a small town in Southeast Kansas. My parents still 

reside there. And they own hardware store in our farming community, as they have for over 38 years. My parents taught me the 

value of hard work and integrity. If confirmed as a Commissioner, 

I will bring all of the values of my Kansas roots with me to the 

Commission. 

During my career, I have also had the opportunity to work in the 

futures industry. It is a fascinating world which is constantly 

changing and innovating. For example, when I started working for 

the Chicago Mercantile Exchange in 1998, its electronic platform 

was used for overnight or after hours trading and the electronic 

volume was less than 15 percent of their total volume. Today millions of contracts a day are traded electronically on the CME with 

a system that trades virtually 24 hours. 

Fortunately, when Congress was tasked with reauthorizing the 

CFTC in 2000, they saw an industry that was quickly evolving and 

they created a framework to give the CFTC the appropriate regulatory tools to keep pace with the development in these markets. 

The Commodity Futures Modernization Act, and my work on it, 

5

fundamentally shaped my view of how the Government can and 

should interact with these markets. The CFMA unleashed the 

power of the free market on the futures industry without sacrificing a rigorous enforcement structure at the CFTC. 

The CFTC does an outstanding job of encouraging market growth 

and innovation while ensuring the integrity of the marketplace and 

protecting market users. The agency has taken their mission very 

seriously and they pursue aggressive action against wrongdoers in 

the markets. 

My regulatory philosophy rests on some of the basic principles 

Congress stressed during the CFMA, fair and flexible supervision 

while providing strong and independent oversight. 

Congress got it right in CFMA. It did it through encouraging 

competitiveness and ensuring legal certainty. Congress, in its wisdom, understood the truth that American entrepreneurs and traders are the best in the world if given the opportunity to succeed. 

Whether you are a farmer trading wheat in Kansas City or a 

trader in Chicago buying Treasury bonds, the CFTC regulates each 

market with the proper level of oversight. Every one of these contracts traded on each futures and options exchange in the United 

States plays an important role and every market participant deserves to have confidence in the integrity and efficiency of those 

markets. 

I understand that there are some challenging issues facing the 

Commission, but as a mother of three small children I know how 

to handle a challenge. I look forward to the opportunity to work on 

the numerous significant matters on the Commission agenda today 

and in the future. 

If confirmed by this Committee and the United States Senate, I 

will work hard to ensure that the CFTC continues its role of encouraging efficient, transparent and financially sound futures and 

options markets while protecting the public from fraud, manipulation, and abusive practices. 

Thank you for the opportunity to appear before you today. I look 

forward to answering any questions you may have. 

[The prepared statement of Ms. Sommers can be found on page 

22 in the appendix.] 

Chairman HARKIN. Thank you very much, Ms. Sommers. 

Now we will turn to Mr. Chilton. I also know that Mr. Chilton’s 

wife, Sherry, is here with us. We welcome you to the hearing. 

Again, Mr. Chilton is no stranger to many of us here. He has a 

long history of working both in the House and the Senate and on 

all matters of agriculture, worked for Dan Glickman when he was 

down there as Secretary of Agriculture, he had a lot of dealings 

with him at that time. And then came up here and was staff member to Senator Daschle during the writing of the 2002 Farm Bill 

and was very instrumental in that. And since then, he has worked 

for the Farm Credit Administration and also the National Farmers 

Union. 

So a long history of being involved in all matters agriculture and 

those attendant thereto. So we welcome you, Mr. Chilton. Your 

statement will be made a part of the record in its entirety and if 

you could summarize it in several minutes, I would appreciate that. 

6

STATEMENT OF BARTHOLOMEW H. CHILTON, OF DELAWARE, 

TO BE A COMMISSIONER OF THE COMMODITY FUTURES 

TRADING COMMISSION 

Mr. CHILTON. Thank you, Mr. Chairman. 

And I do have a couple of letters, one from Senator Daschle and 

one from Secretary Glickman, that I would like to be part of the 

record if that is appropriate. 

Chairman HARKIN. Yes, I just have the one from Senator Daschle 

and one from former Secretary Glickman. They will be made a part 

of the record. 

Mr. CHILTON. Thank you, sir. And thank you, Senator 

Chambliss. And thank you, members of the committee, for taking 

the time to be here. I know your schedules are busy. 

I also want to thank specifically Senator Harkin for his many 

personal and professional kindnesses over the years. I have learned 

a lot from him and will always remember working with him on the 

2002 Farm Bill. I very much appreciate it, sir. 

I also want to thank Senator Reid for recommending me to the 

President. And I want to thank President Bush for nominating me 

for this important position. 

Last, I would like to thank my friend, Tom Buis, for being here. 

And of course, my best friend in life, my wife Sherry, who you recognized, and also is a former Senate staffer. She worked here for 

10 years for Senator Simon and for Senator Kohl. 

I came to Capitol Hill in 1985, and a couple of years after that 

I was asked to work with Congresswoman Jill Long, who Senator 

Lugar, of course, knows and Senator Harkin and others. She was 

a freshman and she asked me to do agriculture work. So I said yes. 

And within a couple of weeks we had passed an amendment to require that exchanges get CFTC approval before they took certain 

emergency actions. It was a very controversial amendment and the 

exchanges quickly dispatched dark-suited lobbyists with cell 

phones the size of shoe boxes to defeat the Long amendment. And 

they did a really good job. 

By the time we got to the full Committee and the opening statements were done, it was apparent that the Long amendment was 

cooked. So all day I went to work with the staff of then–Congressman Roberts and then–Congressman Glickman and tried to resolve 

it. 

Chairman de la Garza would lean down and look at the intern 

desk, which is where they put—Jill Long an additional member of 

the Committee. He would look over the dais and say, ‘‘Is the Long 

amendment ready yet?’’ And of course, it never was. Not until the 

eleventh hour, when we finally got the compromise passed. 

The Chairman was just about to gavel the markup to a close. 

And Jill who, as you all know, is very gracious, did sort of a 

Columbo moment and said, ‘‘One more thing, sir. I would like to 

thank the members for their patience and let them know that this 

was my first amendment passed in the Agriculture Committee.’’

Chairman de la Garza said, ‘‘And let it be the last. This meeting 

is adjourned.’’

[Laughter.] 

Mr. CHILTON. Well, I have learned a lot since that time, both as 

Chairman Harkin said, 10 years in the House, six years in the 

7

Clinton Administration, the Executive Branch, four years on the 

Senate side and then a year at a financial regulator. I hope to 

bring those sorts of experiences about how to pass laws and not 

pass laws, how to promulgate regulations, how to implement them, 

how to enforce them to the CFTC, should I be confirmed. 

But a lot has changed in the futures industry since that time, 

too. We have moved from the pit trading to electronic trading. In 

fact, about 50 percent of trades are now done electronically on 

many of the exchanges. We have seen numerous innovations in different contracts. They have gone from about 200 different contracts 

to well over 1,500 contracts. And amazingly, in a single day, a single day, over $4 trillion changes hands in the U.S. futures industry. 

Just amazing. 

Who would have thought 20 years ago that we would be trading, 

Tom, carbon sequestration credits or weather futures based upon 

heating and cooling days. It is just amazing. 

That said, agriculture remains a really important part of the futures industry. It is less than it was at the beginning, of course, 

and less that was in the 1970s. It is about 7 percent of the total 

portfolio right now. But it still remains very important for not only 

risk management but for price discovery, for farmers, ranchers, 

merchandisers, suppliers, everybody in the agriculture chain. 

With regard to global markets, we have seen global futures exchanges pop up all across the world and the volume increase. And 

many of these exchanges we have U.S. investors involved, and they 

have different regulatory regimes at all of these exchanges. So to 

the extent that it is possible, we need to try and harmonize these 

various regulatory regimes to ensure that U.S. investors’ funds are 

protected. 

So in summary, Mr. Chairman, I would like to use my experience 

I have gained at the CFTC to try and encourage and promote open 

competitive, effective and efficient markets. And as Ms. Sommers 

said, to do that in a way that they are resistant as possible to 

fraud, abuse and manipulation. 

My final caveat, sir, is as a former Senate staffer, I will say that 

I will only do that, I will only do that given the specific authority 

of this Committee and the entire Congress. 

I would be pleased to try to answer any questions. 

[The prepared statement of Mr. Chilton can be found on page 20 

in the appendix.] 

Chairman HARKIN. Thank you both very much for excellent 

statements. And we will enter a round of questions. 

First, for both of our nominees, in 2000, the Commodity Futures 

Modernization Act inserted into the Commodity Exchange Act new 

provisions which exempted from CFTC oversight agreements, contracts, and transactions in energy and metals traded on an electronic exchange between large traders. This exemption is often referred to as the ‘‘Enron loophole’’ since it was inserted into the law 

at the request of the Enron Corporation and others. 

Would you support legislation to eliminate the Enron loophole 

and make electronic exchanges that trade energy commodities subject to the same statutory requirements as regulated exchanges 

that trade energy commodities in order to prevent price manipulation and excessive speculation? 

8

Mr. Chilton? 

Mr. CHILTON. Thanks for the question, Senator. 

There was this report earlier, that Senator Coleman’s Committee 

did, and it’s very troubling. I have not read the report but I have 

read the news reports of it. And it is essentially leading down that 

road. I think it is definitely something we need to look at carefully. 

Currently, the CFTC’s jurisdiction only deals with these regulated markets. And the only way that they can get into these other 

markets, these over-the-counter markets, is if somebody is trading 

on one of the regulated exchanges they can ask for all of their holdings, their cash, and any other positions they might have over-thecounter. 

So I think the first thing you would want to do is have more 

transparency and learn what exactly the extent of that is. I have 

learned over the years that you have got to be careful about a 

quick legislative fix. I would be concerned that if we do something 

that is too prescriptive, we might ultimately drive people away 

from our markets, drive them overseas. 

That said, this report is very troubling, or at least the news accounts of it are, and I think we need more information to see if 

that is something that we should move forward on. 

Again, this is totally in the purview of Congress. The CFTC does 

not currently have that authority, as you correctly stated. So as a 

regulator, should I be confirmed, I will do whatever Congress tells 

me to do. 

Chairman HARKIN. Ms. Sommers, same question. 

Ms. SOMMERS. Thank you, Senator Harkin. 

I guess, first of all, I would start out by saying that I think the 

Enron situation was a result of bad business practices that would 

not be condoned or promoted by a U.S. regulatory agency, and certainly there is no excuse for what happened there. 

I also would join Mr. Chilton in saying that if Congress deems 

it necessary for the CFTC to have the authority to regulate these 

markets, as a Commissioner at the Agency, I would be a rigorous 

enforcer of those regulations. I think that we need to be careful and 

have a fair and balanced approach when you are regulating these 

markets. 

But if it comes to protecting the users in markets from fraud and 

abuse, I think that is absolute something that the Commission 

needs to do. 

Chairman HARKIN. Let me follow that up then with both of you. 

Ms. Sommers, since NYMEX is regulated by ICE is none, and since 

trading on one affects the other, what kind of sense is there that 

we would regulate one and not the other? Why would we regulate 

one and not the other, is my question? Do you have any basis of 

support from a regulatory standpoint of why it would be advisable 

to continue to regulate one but not the other? 

Do I need to rephrase the question? 

Ms. SOMMERS. No, I understand your question. 

I guess I would say that those exchanges, the ICE futures exchange, it is my understanding, is a regulated entity by the FSA 

in London. The products that they offer, which are over-the-counter 

derivatives, are of course not regulated because, as you put it, it 

9

was in the Commodity Futures Modernization Act that those products would not be regulated. 

Chairman HARKIN. I am just saying from a regulatory standpoint 

is there any reason why one should be under CFTC regulation and 

the other not, is what I am trying to—is there any reason regulatory-wise why that should be? 

Ms. SOMMERS. I think they are different products. The derivatives contracts could be different than what is traded on a standardized contract on a regulated futures exchange. 

Chairman HARKIN. Both of them trade energy commodities. 

Ms. SOMMERS. Yes, sir. 

Chairman HARKIN. But what is related by CFTC and one is not. 

Mr. Chilton, do you see any regulatory reason why there should be 

one regulated and one not? 

Mr. CHILTON. it seems odd to me, sir. But again, I think if you 

did it, you would want to be prudent in how you would do something like that. In Congress’ wisdom they excluded these things. 

And so you might want to look at the history as to why that was 

done. 

But I think it is a good question and it is, like I say, before you 

just say let’s do it and make a legislative fix and let’s just put it 

in an extension of CFMA. I think you want to be careful about how 

you do that. You certainly do not want to drive people away from—

I mean, the commodities industry is important to our economy and 

we do not want to scare people off and have them go overseas. 

But by the same token, I think your question is a really good one 

and I cannot give you a good reason regulatorily why it could not 

be implemented, certainly. 

I would put one caveat in there, sir, the CFTC has lost about 60 

employees since 1976. The SEC has about 3,600 folks. So if you are 

going to do any regulatory change, I mean they are already a 

strapped agency. And I have not been down there long enough to 

be a shill for them. But I have been there long enough to understand these sorts of numbers, losing 60 people since 1976. They 

have only 536 folks down there. So if you ever expand their authorities in any regard, it seems to me you are going to have to 

work with the appropriators and make sure the resources are 

there, also. 

Chairman HARKIN. Thank you. My time has run out. I recognize 

Senator Chambliss. 

Senator CHAMBLISS. Let me follow on that a little bit, Mr. 

Chilton. Mr. Greenspan, former Chairman of the Federal Reserve, 

has spoken of the benefits of derivatives markets and specifically 

says that ‘‘Derivatives market lessen the vulnerability of individual 

financial institutions to shocks from underlying risk factors.’’

He also has said that ‘‘Derivatives markets have increased the 

resilience of the entire financial system.’’

Do you agree that the use of derivatives has improved the flexibility and stability of the financial system? 

Mr. CHILTON. Yes, sir. 

Senator CHAMBLISS. It has been awhile since I have looked at 

this but as I remember there was an issue relative to the validity 

of swaps and derivatives if they came under regulatory scrutiny. 

And I concur with you that we had better be careful before we ever 

10

think about doing that, particularly, as you say, with a limited 

number of employees that are able to do the scrutiny. 

Ms. Sommers, you have held several positions within the industry regulated by the CFTC. Would you please share with this Committee the roles you assumed in these capacities and how these experiences have prepared you to serve as a Commissioner? 

Ms. SOMMERS. Thank you, Senator. 

I started my career in the industry with a regulated exchange, 

the Chicago Mercantile Exchange, and was able to learn the business from a designated contract and self-regulatory organization’s 

point of view. 

I also had the opportunity to work for the International Swaps 

and Derivatives Association, an association that represents many 

of the investment banks that are participants and users of the marketplace and have an, I think, unique perspective because in many 

of the cases I have a sometimes opposite point of view that my 

background gives me from working with those two organizations. 

I view my experience as a benefit to the Commission, not an impediment to my independence or my independent judgment as a 

Commissioner. 

I view the mission of the agency very seriously to protect market 

users and to protect open and competitive markets. 

Senator CHAMBLISS. You have, in your capacity being in the industry, obviously you have been employed in different aspects of it. 

And now as a Commissioner you may be on the other side of some 

of those entities that you have worked for and you will be regulating those particular entities. Are you telling the Committee 

today that you are willing to put aside any feelings you have from 

an employer/employee relationship and you are willing to be independent in looking at each of these agencies and whatever issues 

relative to them may come before the Commission? 

Ms. SOMMERS. Absolutely, Senator. 

Senator CHAMBLISS. Mr. Chilton, as you know, in 2000 we passed 

the CFMA. And now we are looking, as we did last year, we are 

looking again at the reauthorization of the CFMA. I think it has 

been generally agreed in the industry that there has been significant growth and innovation that was allowed by the CFMA. 

As we look at free authorizing the CFMA, do you have any 

thoughts or comments or suggestions of anyway that you think we 

can improve it? In other words, we have had some people on this 

Committee who have advocated a one-line extension of the CFMA. 

And then we have others who want to go into more details about 

it. Do you have any comments relative to that? And then Jill, I will 

ask you the same question. 

Mr. CHILTON. Thanks for the question, Senator. You are correct, 

it has been a resounding success. I think those who helped take 

part in it should be proud of it. 

I think the Senate bill that was passed last time was a good 

piece of legislation and I think if you move down that road you will 

be fine. A one line extension would be all right but I think it does 

not take care of some of the things that the Senate was interested 

in doing, dealing with the Forex issue with regard to the Zelener 

loophole and potentially clarifying some of the fraud statutes in the 

law. 

11

But other than that, sir, the Senate bill did those things and I 

think the Senate bill did a good job. 

Senator CHAMBLISS. Ms. Sommers? 

Ms. SOMMERS. Senator, I certainly agree with the Bart on that 

answer, going through the Senate bill. I know that the CFTC was 

particularly interested in making sure that their fraud authority 

was clarified under Forex issues and additionally making sure that 

those markets, the integrity of those markets are protected is what 

their mission is. So I know that would be helpful to the Commission. 

Senator CHAMBLISS. To both of you, let me say your willingness 

to commit yourself to continued public service is admirable. We appreciate it very much and we look forward to your confirmation 

and your service on the Commission. Thank you. 

Chairman HARKIN. Thank you, Senator Chambliss. Senator 

Lugar. 

Senator LUGAR. Thank you very much, Mr. Chairman, for calling 

this hearing. 

I would just reminisce for a moment that at the time that I was 

fortunate enough to come onto the Committee in early 1977, the 

table seemed to stretch all the way down from one end to the other. 

On one side was my dear friend, Pat Leahy. I was on the other 

side. And we were so remote from the Chairman, Herman Talmadge, and Jim Eastland who would smoke up here. And they 

would be caught in a cloud of smoke and suddenly the meeting was 

over, the meeting had been decided. 

But one day they made a concession to the juniors at the end. 

This Commodity Futures Trading Corporation Act had been passed 

and no one paid much attention to it and some felt there should 

be oversight. And so we were assigned to that. 

Of course, we took our duties very seriously, perhaps too seriously for our seniors on the whole business. But it has led me to 

a Senate lifetime of very deep interest in what you are doing. 

When the Chairman got into today the energy question, this is 

an area that has either plagued or bedeviled the Committee and 

the Commission for a long time. It was not by chance that energy 

was exempted even in the last go round, nor in some before. There 

were very strong senators and other interests who simply felt that 

it was inappropriate and they did not want the regulation. 

The Enron business brought things to the fore and I think, Bart, 

that you are correct that before you rush into this you need to 

think about what you are doing. 

But I would hope that the Commission and the Congress would 

take seriously the problems that continually arise and not just simply in Enron but difficulties that are more current that you reference today. 

I am grateful that you, Mr. Chilton, have a good Hoosier background out of Purdue. This is reassuring. And I see behind you the 

President of the National Farmers union who likewise claims Hoosier roots and was recently on my farm for a period of Earth Day 

celebrations with the Chicago Climate Exchange. So we are grateful to be reunited here today. 

I have no further comment except to plea that we be courageous 

enough to step up to the energy questions. They are going to beVerDate 0ct 09 2002 10:40 Nov 16, 2007 Jkt 000000 PO 00000 Frm 00015 Fmt 6633 Sfmt 6633 C:\DOCS\38703.TXT SAG2 PsN: SAG2
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come bigger and bigger. We had one period in which our Committee had extensive hearings with Alan Greenspan and others 

about derivatives. It was the time of the Capital Management fiasco and the whole banking system in the country was in jeopardy. 

We have never quite come to grips with all the indications of that, 

even given reassurances at the highest levels. 

The two of you both have experience in this and you can make 

such a difference, not only in public life but in this specific agency. 

I thank you, Mr. Chairman. 

Chairman HARKIN. Thank you, Senator longer. Senator Coleman. 

Senator COLEMAN. Thank you, Mr. Chairman. 

On Monday, the Permanent Subcommittee on Investigations, of 

which I am the ranking member, held a hearing and released a report entitled Excessive Speculation in the Natural Gas Market. 

This was a bipartisan report. Chairman Levin and my staff examined the trading of a single hedge fund, which was Amaranth, LLC 

and revealed serious problems in the current regulation of our natural gas markets. 

I am deeply concerned about the integrity of the energy markets 

and what appears to me a large gap in our regulatory structure. 

What we saw in this investigation was in August, last August, 

NYMEX became concerned that Amaranth’s holdings in natural 

gas positions had become too large and NYMEX ordered to reduce 

their NYMEX holdings. About one point in time Amaranth held 

about 100,000 contracts on the ICE and NYMEX, 75 percent of all 

outstanding future contracts to deliver natural gas on in November 

on NYMEX. It is pretty overwhelming. So Amaranth gets told by 

NYMEX to reduce its holding. They had no choice but to comply. 

But rather than reduce its overall exposure in the natural gas 

market, they simply shifted its natural gas positions and holdings 

to unregulated OTC exchange where positions and limits and accountability limits do not apply. 

So of course, the concern is if traders can avoid regulation by 

simply shifting their large positions to unregulated OTC markets, 

which is what you have with ICE, then the CFTC’s ability to monitor and prevent excessive speculation and price manipulation is 

undermined. 

I do notice that the CFTC has now proposed traders report details from exempt markets, which I think is certainly a step in the 

right direction. 

I would note that our report revealed that Amaranth’s activities, 

these were not victimless crimes. Ultimately this was $2 billion in 

natural gas holdings, an $8 billion portfolio wiped out. But consumers were impacted. The price of natural gas shot up by speculation, so it was the consumer who really was hurt by this. 

The question is how to move forward. 

Mr. Chilton, I appreciate your reflection that there are—what are 

the unintended consequences? The question was asked why should 

we not regulate both? I actually think we should get rid of the 

Enron loophole. But let us be aware that we could do NYMEX and 

ICE, but then you folks can shift to other markets, can shift to the 

London market. There is a lot of bilateral stuff that is not electronically recorded. 

13

So I just think we have to be very, very aware that if we want—

and I appreciate Senator Chambliss comments. Speculation, it provides liquidity in the market which helps consumers. This is not 

about protecting gamblers, speculators being gamblers, but it is 

about having liquidity in markets that consumers benefit. We benefit if you can buy lower in August or September for what may be 

a very cold winter in Minnesota and Iowa in January. 

So that is the concern that we have. 

In my short time, just two questions. One, there was a lot of support expressed for Congress giving CFTC authority to expand its 

regulatory reach and they called for regulation of the OTC exchange. 

One, do you believe that—two things. One, there is—and I appreciate your issue about the cost of enforcement. We have to really—

when you give the CFTC this authority, we better make sure they 

have the ability to handle that. I would be interested in both your 

perspectives and on whether if we would extend it just to those 

two, would that increase transparency enough? Should we be looking beyond ICE? And if so, where do we draw the line? Mr. Chilton 

and then Ms. Sommers? 

Mr. CHILTON. I do not have a great answer for you, Senator, but 

you are absolutely right. If you go to the bilateral exchanges, those 

are just done over the phone. Those are totally in the dark. Those 

are removed. 

So if we are thinking well, let us go require something at ICE, 

maybe that would work for a little bit if you were not too prescriptive and people did not leave the market and go other places. But 

they might just shift to some place that you will never see. 

So these are sort of vexing questions and it is interesting hearing 

Senator Lugar talk about how people dealt with this through years 

and years. But it seems to me that energy is not just important 

right now with the high cost of fuel, but it is going to be more and 

more important. 

And the number of products that are going to come online. Again, 

we talked about carbon sequestration. You have wind. There are an 

enormous amount of products that are going to come online. So we 

need to take this very seriously and I thank you for your interest 

in it. 

I wish I had a more detailed answer for you, sir. 

Senator COLEMAN. I look forward to you reading the report and 

we will have a further discussion. 

Ms. Sommers? 

Ms. SOMMERS. Thank you, Senator. 

I also understand your concerns in this area. And I agree with 

you that this is an issue that is important to the Commission and 

important to Congress and something that we need to look at closely in the future. 

I just will note something that Senator Harkin noted in his remarks. The CFTC’s Enforcement Division does a great job in enforcing the Act and the regulations in the Act and the authorities 

that they have. And they have, in the last five years, opened more 

cases than in the history of the agency. So they a strong record. 

Senator COLEMAN. Mr. Chairman, would you allow me one further question? Again, we spent a lot of time in this hearing and it 

14

is a good opportunity, it is very, very timely, if Senator Thune 

would permit. 

There was rather blistering criticism of the CFTC in that, in particular Professor Michael Greenberger, University Maryland Law 

School. He said you have vacancies coming up. It is traditional that 

anybody who supports the industry gets passed on on the Senate 

floor by a voice vote with no discussion. He said but are there going 

to be industrial consumers represented? Are there going to be regular consumers who are represented? Are they going to be academics? 

If you represent—and I am not exact quotes, but taking parts of 

his testimony. If you represent the consumer, you get stopped. If 

you are helping the banks, you sail through. 

Ms. Sommers in particular, you come from a background where 

you have been involved in the swaps and futures industry. Is that 

a detriment? Can you effectively represent consumers if you have 

worked with the industry? How would you respond to that? 

Ms. SOMMERS. Senator, I think that I can say from my experience, I have worked with the CFTC for over 15 years. I think you 

look at the structure that they have at the agency. They have advisory committees. 

And if you look at the participants in those advisory committees, 

there are users, there are producers, there are producer groups. 

Everybody is represented at the table. When the agency looks at 

difficult issues that are affecting the industry, they are hearing 

from everyone. 

I think they do a good job in their role of protecting the consumers. 

Senator COLEMAN. Mr. Chilton, do we have to do something in 

terms of the structure of the CFTC to ensure that the consumers 

voice is heard and reflected upon? 

Mr. CHILTON. Not that I know of, sir. It seems to me that there 

is an open process. There is an open regulatory process like there 

is in any Federal agency that goes on. 

I did read those comments in the press report and it sort of troubled me, not in particular about myself. I will say that the two 

Commissioners that are there right now, both Commissioner Dunn 

and Commissioner Lukken, both former staffers of this Committee 

by the way, they are in nobody’s pocket. I have worked with them 

for years and I have tried to get them to do things and they do not 

want to have anything of it. 

So I hope to be independent when I get there and I am sure Mr. 

Sommers does also. 

Senator COLEMAN. Thank you. I thank both witnesses and nominees and I think the Chair. 

Chairman HARKIN. Senator Coleman, I appreciate that question 

on consumers because I was going to ask that same thing myself. 

Senator THUNE.

Senator THUNE. Thank you, Mr. Chairman. And thank you, Ms. 

Sommers and Mr. Chilton, for putting yourselves forward for public 

service. The CFTC is obviously an important agency and plays a 

critical role in maintaining transparency and competitive and economically sound futures and options markets. 

15

It is the watchdog, the enforcer of laws that govern our markets. 

Accordingly, the members of the Commission need to provide objective and independent judgment and analysis that protects the 

American public and investors from fraud in the financial marketplace. 

I think it is important that these positions be filled. The CFTC 

is, I think, handicapped by some of these long-standing vacancies 

and without a full Commission has limited ability to carry out its 

mandated mission to protect consumers from fraud and abuse. So 

I hope that this Committee can move quickly to get these positions, 

to get you all confirmed and in there so you can go to work. 

Just a couple of questions if I might. Has excessive speculation 

contributed to volatility in the futures market? And if so, what does 

the CFTC need from Congress in terms of more authority to address the issue? There is a view out there, widely held I think, at 

least in some quarters, that there is a lot of speculation that in 

some ways contributes to the volatility. 

I am curious to get your take on that and what Congress might 

be able to do to address that? Either of you or of you. 

Mr. CHILTON. Mr. Chairman and Mr. Thune, it is an issue but, 

as Senator Coleman said, it is a double-edged sword. You need 

enough speculation in the market that you provide liquidity, which 

provides capital, which provides enough so people can hedge. So it 

is sort of a vexing question. But Congress actually did something 

sort of interesting. Manipulation is actually listed in the statute as 

against the law. You cannot do it. 

On speculation, sir, it is really regulatory—there is a rulemaking 

process. So over three decades it stayed like that. It may be because—I don’t know. It may be because it is so difficult to define. 

What is too much? 

I think the CFTC has done a pretty good job over the years. But 

that does not mean that there are not issues like the one that Senator Coleman talked about that we need to look at that really were 

not around years and years ago. 

I hope that answers your question. 

Senator THUNE. Ms. Sommers, do you want to respond to that? 

Ms. SOMMERS. Sure. Senator Thune, I think when you look at 

the position limits in markets, that is something that the exchanges, which are self-regulatory organizations, all have excellent 

market surveillance programs. And the exchanges themselves have 

a great deal to lose if their market integrity is ever called into 

question. 

They are protecting their name and their markets from abusive 

practices and they are looking at these position limits and looking 

at the traders in the market. And they set those limits to where 

they know that it is going to create a liquid market without sacrificing the integrity of their markets. 

Senator THUNE. It is probably a fine line to try and determine 

the difference between speculation and manipulation, speculation 

being the legitimate part of the marketplace working. But I did 

want to ask that question. 

What is your view on the relationship between the SEC and the 

CFTC? Do those roles overlap? And if so, do you think that can be 

16

addressed to ensure that there is efficiency if there is not overlap 

in the way the agencies function? 

Mr. CHILTON. Thanks, Senator, for the question. 

You know, they are similar in some regards but they have different mandates and different laws. I read some of the news reports this morning that you probably have that somebody at the 

SEC was talking about potentially merging. I do not know that you 

ever get cost efficiencies when you do that. There are, for example, 

subject matter experts at the CFTC. They are looking at these individual products, some of those that I mentioned in my opening 

statement, weather futures, et cetera. It is sort of a different function than the SEC has. 

Tony Blair tried this and did actually merge agencies over there. 

And as far as I can tell, there is no cost savings. So I think you 

have to be wary of it as you move forward. 

Chairman HARKIN. Ms. Sommers. 

Ms. SOMMERS. Thank you, Senator. 

I think that when Congress created the SEC and then later the 

CFTC, had they known what the evolution of these markets would 

look like now, they could probably look back and say maybe we 

should have done this differently. But the products now, a lot of 

times, are definitionally blurred. And it is a difficult question. 

But the CFTC has enormous differences from the SEC and they 

are experts in what they do over there regulating the derivatives 

industry. And I do think, as Bart said, I am not sure that it is 

something that would create the efficiencies that we see from the 

outside. 

Senator THUNE. One last question if I might, Mr. Chairman. Mr. 

Chilton, in your testimony you mentioned the need to harmonize 

market regulations with foreign regulatory bodies. What steps does 

the CFTC need to take to achieve that goal? 

Mr. CHILTON. Well specifically, people do not have the same—not 

all exchanges have the same sort of standards we do. For example, 

capital requirements on margins, et cetera. They do not have the 

same—some of them have record-keeping but they do not have regulation. 

So when I talk about harmonizing, I am really not talking, Senator, about reducing our standards. I am talking about trying to 

ensure a harmonized regulatory regime worldwide that protects 

U.S. investors who want to put their money in overseas exchanges. 

Senator THUNE. Mr. Chairman, thank you. And again, thanks to 

our nominees and we look forward to working with you. Hopefully 

we will get you confirmed quickly. Thank you. 

Chairman HARKIN. Thank you, Senator Thune. 

I just wanted to read this on the report that came out here that 

Senator Coleman was talking about. It was a very good report but 

I would just read one sentence. It said ‘‘To continue the present situation, in which the CFTC does not police two of the three major 

markets trading U.S. energy futures is to turn a blind eye to an 

increasingly large segment of these markets, thereby impairing the 

ability to detect, prevent, and prosecute market manipulation and 

fraud. The United States needs to put the cop back on the beat in 

all of those key energy markets.’’

17

Well, you are the cop and we need to figure out how we can get 

you back on that beat. 

One last thing on speculation. I continue to hear from ag producers and now I am hearing from ethanol people about the fact 

that a couple of years ago the CFTC raised the speculative limits 

on positions held in agriculture futures contracts. Now there may 

be arguments on both sides, but I am hearing more and more from 

ethanol producers and others that this has really put them at a 

great disadvantage. 

So I am just wondering if I could ask would you be willing, if you 

are obviously confirmed, would you commit to taking an independent look at this issue? And would you be willing to re-examine 

the action taken in raising the speculative limits if the facts and 

circumstances support taking another look at this issue? 

Ms. SOMMERS. Absolutely. 

Mr. CHILTON. Yes, sir. 

Chairman HARKIN. Do you have any other elaboration on that at 

all? 

Mr. CHILTON. Well, I mean, there is only certain commodities 

that—and Ms. Sommers may be able to help me out on it. But 

there are only, I think, nine commodities where actual limits are 

not set by the exchanges themselves. I think what you want to be 

careful about, sir, is you do not want the Federal Government to 

be the price setter for these things. By setting limits, you may have 

some impact on that. That gets into a scary area. 

So I think you want to be careful but it is absolutely something 

that I would be pleased to look at and would like to look at. 

Ms. SOMMERS. Yes, Senator, I do agree that I would be happy to 

look at any specific issue. But I do think that in some of the cases 

in commodities, those position limits are set by the exchanges 

themselves and they are given to the CFTC as an internal rule 

change for the exchange. The exchanges have their own market 

surveillance programs and, as I said in response to Senator Thune, 

they have a lot to lose if they lose the integrity of their markets. 

When they change position limits in a contract, it is because of the 

way that contract is trading. 

They have the on the ground expertise, I guess is what I am saying. And so we would want to work closely with the exchanges to 

make sure that their own internal rule changes are not something 

that are adversely affecting the customers in that market. 

Chairman HARKIN. Very good. Senator Lugar. 

Senator LUGAR. Mr. Chairman, I just want to follow through on 

a comment that you just made. In some of the ag newsletters that 

I read each day, the comment is made again and again that we are 

in a new period of time in terms of trading, perhaps due to ethanol 

or the energy business entering into it, in which analysts say in the 

old days we used to look at weather, the amount of planting of various crops, some fundamental things with regard to the feeding of 

livestock, even the export markets disappearance that way. 

But now you have a virtual revolution in terms of expectations 

on markets, as well as with farmers and other producers, in which 

this phenomenon really has not been surveyed because it is still 

maybe a revolution underway, this particular year being a good 

18

case in point, with the price of corn being roughly $1.50 a bushel 

more. That is a huge change in a single year of time. 

I just wonder, Mr. Chairman, whether this is not something that 

we are asking the regulators to regulate, although clearly some of 

the anxiety with regard to the swings day by day that come from 

all of this do bring some anxieties. And that is a part of a speculation and the price setting. 

But it may be at some point an oversight hearing by the Committee in which we sort of examine this remarkable year in which 

we are now involved. Maybe we have to have some of our own 

benchmarks to see how it all works out, might be helpful. So that 

we do not overregulate. But then if some changes are needed in 

your regulations or in basic legislation, we are in a better position. 

Because I sense, perhaps as you do as very careful students of 

the market, that this is a very exciting time to be trading. But at 

the same time maybe so exciting that sometimes things may come 

off the track where deliberate harm occurs in various markets. 

So this is just my own speculative comment, that this might be 

worthy of our study at some stage just to get a fix on it so that 

we are all better informed and from our own prejudices do not rush 

off in some direction. 

Chairman HARKIN. Thank you very much, Senator Lugar. That 

is a good suggestion. I just hope we can maybe get through the 

Farm Bill first and then we can take a look at that at that point 

in time. 

[Laughter.] 

Chairman HARKIN. I have a feeling we are going to have a long 

fall here so there are a lot of oversight things we can look at at 

that time. 

If there are no other questions, I would just say that—and I hope 

staff and Senator, I hope you do not think this is unreasonable but 

I will propose this, that all questions for the record submitted to 

these nominees be submitted prior to six o’clock this evening. That 

way we can get them to the nominees and they will have tomorrow 

to respond to those questions. If that works then possibly we can 

get the nominees discharged from the Committee even before the 

week is out, if that is okay. 

Senator LUGAR. I have no objection. I do not know if any of the 

staff representing other senators have any objection. 

Chairman HARKIN. We had a pretty good turnout here today so 

I am not certain if anybody has any more questions. But if they 

do, get them to my staff, get them here prior to six o’clock and we 

will get them to the nominees and we will ask you to respond as 

rapidly as possible. The more rapidly you respond, the sooner we 

can get you discharged from the Committee. 

If there are no other questions then, again I thank both our 

nominees. I join with my fellow Senators in thanking you for your 

long service and public service here on the Hill and other places 

and thank you for your willingness to serve on the CFTC. Hopefully, we can move this expeditiously. 

With that, the Senate Committee will stand adjourned. 

[Whereupon, at 3:01 p.m., the Committee was adjourned.] 

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