Conflicts and Affiliations
Methodology
Source of record. Everything on this page is drawn from the official public record — the docket linked above. Every filer row links to the original filing. PMP’s counts, excerpts, and classifications are interpretive aids and should not be quoted in place of the source; when citing, link to the original document.
Counts. “Posted” counts comments visible on the official record; “received” is Regulations.gov’s count of submissions the agency reports having taken in. The two are different units, so the difference between them is not simply a backlog. Three things separate them, per the Regulations.gov FAQ: staff screen each filing (for duplicate or near-duplicate campaign copies, private or proprietary information, and inappropriate language) before it appears publicly — typically within a day or two, though waits of two to three weeks have occurred; a single filing whose attachment is declared to represent multiple submissions is posted once but counted many times as received; and agencies may withhold near-duplicate copies of a mass-mail campaign, which then never post at all. A large gap most often means an organized campaign reached the docket — it does not tell you how many distinct letters are still to come. The SEC generally posts letters within days and discloses no received total.
Freshness. The record on this page is refreshed as filings post to the official record; the “Updated” line shows the most recent refresh. The received figure updates about once a day at its source.
Documents. Each filing is captured in full — the comment text and every attachment — and attachment text is extracted for reading and search. A filing whose attachment cannot be machine-read is flagged rather than treated as saying nothing.
Filings made with both agencies. Comments on this joint request could be filed with either agency, and many filers submitted the same letter to both. A filer whose letters to the two agencies are near-identical appears here as one filing — the row links the CFTC docket copy on Regulations.gov, with the SEC copy on sec.gov alongside — so the filing count on this page counts distinct filings, not official-record entries, and is smaller than the two venues’ posted counts added together. A filer whose letters to the two agencies differ in substance keeps a row for each.
Filer cohorts. The cohort on a filer row (and behind the cohort filter) is PMP’s classification of who is speaking — assigned from the filing’s own signature block, letterhead, or self-description, and published only when that evidence appears word-for-word in the filing. Filers claiming no affiliation, and organized-campaign copies, are counted as individuals. Filings classified as CFTC-registered entities are additionally cross-checked against PMP’s registration tracker (DCM, DCO, FCM, and IB registrations and applications). Cohorts are PMP’s inference from the record, not a designation on it; a filing with no verifiable affiliation evidence simply carries no cohort.
On this record.
The question grid. The questions are the Commission’s own requests for comment from the proposing release with Federal Register page cites — not categories PMP invented. A filing is counted under a question only when a word-for-word quote from the filing shows it addressed that question; claimed matches that cannot be verified against the filing’s own text are not counted, and no filing is excluded. Identical filings are classified once and counted for each copy on the record. Questions with no verified match are shown, not dropped: no match means no quote from any filing could be verified against the question, not that no filer discussed it.
Stance. Stance is measured against the Commission’s stated position on each question — a filing agreeing with the Commission that it should not act reads as supporting the Commission. A filing that engages a question without taking a side is recorded as stating no position, never assigned one. Exact values are in the table view.
Substantive comments. The “substantive comments” figure counts independent filings — campaign copies excluded — whose text verifiably engaged at least one of the Commission’s questions, by the same quote-verified standard as the grid. Filings that engage none of the questions (brief remarks, meeting memos, filings whose attachments could not be machine-read) stay in the filer list; they are simply not counted as substantive.
Letter campaigns. When many filings are near-identical copies of one template — including lightly reworded copies — they are grouped as an organized letter campaign, detected by text similarity across the full record. The charts default to the independent record, with campaign copies counted separately; the “Include campaign” toggle folds them back in, and every campaign filing is marked in the filer list. A campaign is classified once from a sample of its copies (the sample size is stated on its card), and a position is attributed to the campaign only when the sampled copies agree. Campaign membership is PMP’s inference from the text, not a designation on the official record.
AI assistance. Parts of PMP’s pipeline — text extraction, classification scaffolding, and match drafting — are AI-assisted. Every counted match is verified mechanically against the filing’s own text, and the output is reviewed by PMP before publication. The authoritative record of any comment remains the document filed on the official docket.
Corrections. Filers, journalists, and other parties who identify classification errors can reach us via the contact page.
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