Concurring Statement of Commissioner Caroline D. Pham on Joint Data Standards Proposal

I respectfully concur from the Notice of Proposed Rulemaking on the Financial Data Transparency Act (FDTA) Joint Data Standards ("Joint Data Standards Proposal") to require each respective agency to implement certain data standards for its regulated entities because there is insufficient discussion of the impact and costs associated with the adoption of these new data standards that will apply across the banking and financial services sector (including small entities as set forth under the Regulatory Flexibility Act). While I support the FDTA's mandate, I believe the Joint Data Standards Proposal would be improved by addressing head-on the elephant in the room-the very real costs that will be imposed on potentially tens of thousands of firms of all sizes that will eventually have to update their systems and records to adhere to the new data standards. I encourage all commenters to address the costs and benefits of the Joint Data Standards Proposal, including the necessary future agency rulemakings that will subsequently follow. I thank Ted Kaouk, Tom Guerin, Jeffrey Burns, and the staff of the CFTC, and all the other agencies for their efforts on this proposal.