It may be superfluous, but not overly burdensome. The agricultural trade option training may be worth the time spent and screening for felons has minimal cost. If the reparations program is superior to other methods of customer protection and dispute resolution, then the registration requirement will be serving the objectives as intended. However, it is possible the registration requirement may be retarding the development of a secondary market for agricultural trade options. Imagine a well developed market for agricultural trade options.
Retail ATOMs sell options and bear the risk the producers seek to avoid.
These larger firms are likely doing a large business in CFTC regulatory exempt commodity and financial swaps. They may fear that by becoming CFTC registrants they will jeopardize their exempt status in a prominent part of their current business activity. Thus, while the registration requirements may be appropriate for the retail ATOM business, it may be limiting the potential for the agricultural trade option market to attract wholesalers. Without wholesalers the agricultural trade option market will not evolve to its full potential. No offset The pilot program rules do not permit option holders to offset their positions with a cash transaction prior to maturity.