Review of the Commitments of Traders Reporting Program

The single largest cluster by far: individual retail and independent traders, largely organic (non-templated), asking the CFTC to move from weekly to daily (or at least more frequent) COT publication because the current Friday-afternoon report based on Tuesday data is stale by the time it's read. Many frame COT as one of the only public windows they have into institutional positioning and describe it as central to their own risk management.

• Marc Tannenbaum: “The Tuesday-to-Friday lag is a real limitation in markets that can shift meaningfully within a single session.”
• David Quinn: “This data is very valuable and useful but must be the oldest data left in the world of up-to-the-second market information.”
• Trucker John: “I'm not a professional trader, I drive a truck for a living… The Commitments of Traders Report offers people like me an opportunity to ride the coattails of either the Producers or the Money Managers.”

A smaller set of unusually detailed individual comments went beyond a simple frequency ask to propose concrete operational changes: machine-readable bulk APIs with publish timestamps and revision logs, an official ticker-to-COT-name mapping file, two-tier preliminary/final releases, published trader-concentration ratios, expanded coverage of newer contracts (crypto, event contracts), and phased multi-year rollout timelines. Several cite specific historical stress events (the 2020 COVID dislocation, the negative-WTI settlement, the 2022 UK gilt crisis) as evidence that weekly data was too slow during past market disruptions.

• Slava S.: “Publish a preliminary COT Wednesday evening based on raw unvalidated snapshots, clearly marked 'PRELIMINARY — SUBJECT TO REVISION.'”
• Garner McCloud: “Daily publication is not a new collection burden. Reporting firms already submit position data to the CFTC every business day under Parts 17 and 18.”

The National Cotton Council, Commodity Markets Council, and American Cotton Shippers Association each submitted near-parallel letters (down to shared paragraph structure and phrasing about the report's history from annual to weekly publication) proposing a specific twice-weekly Tuesday/Friday schedule plus more granular trader-category breakdowns, rather than full daily publication. Amcot filed separately purely to endorse the Cotton Council's letter — a coordinated agricultural/commodity-industry position, not an organic grassroots pattern.

• National Cotton Council: “NCC supports the Commission moving to a twice-weekly publication schedule… based on positions at the close of business on Friday.”
• Amcot: “The members of Amcot write in support of the comments submitted by the National Cotton Council.”

The National Grain and Feed Association/National Council of Farmer Cooperatives, the Futures Industry Association, and the North American Export Grain Association all support increased frequency but frame it as a multi-step, sequenced modernization — first refining the catch-all 'Other Reportables' trader category, then shortening the data lag, and only then adding a second weekly report — explicitly to protect data accuracy.

• Futures Industry Association, Inc.: “FIA recommends that the CFTC: (1) enhance the detail, timeliness, and frequency of the COT reports, in phases, to ensure continued accuracy of the reports.”
• North American Export Grain Association: “Even reducing the lag from three business days to one or two business days would materially improve the usefulness of the report.”

Optiver is the one liquidity-provider voice in the docket, staking out a middle position distinct from both the retail 'go daily' chorus and the trade-association twice-weekly proposals: run a time-limited pilot with pre-announced evaluation criteria in only the most liquid contracts, testing daily or even intraday publication, before considering any broader change.

• Optiver: “For many active users, a twice-weekly report would be an incremental improvement but may still be too delayed to materially change how the report is used.”

MFA, representing the hedge fund industry, is the most cautionary institutional voice in the docket. It opposes any move beyond the current weekly Friday schedule until the Commission first proves — through testing — that it can validate and classify data on a compressed timeline without harming confidentiality or accuracy, and separately proposes raising the minimum-trader suppression threshold and adding new sub-categories to reduce identification risk.

• MFA: “The Commission should not move to more frequent publication absent strong evidence that incremental public benefit outweighs increased confidentiality and data-quality risk.”

The National Pork Producers Council supports evaluating faster publication but, echoing MFA's concern from the buy side of agricultural markets, warns that livestock and other agricultural contracts involve fewer reportable participants than large financial markets, making trader identification a bigger risk if frequency increases without added safeguards.

• National Pork Producers Council: “Timeliness and frequency alone should not come at the expense of data integrity or reporting quality.”

Better Markets is the one institutional commenter that pushes for more frequent publication without conditioning it on a pilot or phased rollout. It directly rebuts the Commission's own stated rationale for weekly-only publication, arguing the CFTC has attributed the limit to 'resource constraints' rather than confidentiality risk, and that aggregation already protects trader identity regardless of frequency.

• Better Markets: “The CFTC has not said that concerns with deducing the identity of position holders are what have prevented it from increasing the publication of the COT Reports. Instead, it has said that it is due to 'resource constraints.'”

At least three filers submitted word-for-word identical letters (a fourth is a close paraphrase of the same argument and structure) praising COT as one of the most valuable sources of market transparency and asking the CFTC to keep it free and move from weekly to daily. This is a clear organized/templated submission pattern rather than independent organic comments, though the underlying ask matches the majority organic sentiment.

• Le Wang: “The Commitments of Traders (COT) report is one of the most valuable sources of market transparency available to traders, investors, researchers, and the public.”
• Lionel Greene: “I also encourage the CFTC to consider increasing the reporting frequency from weekly to daily.”

A couple of comments expressed general appreciation for the COT report's role in market transparency and daily trading routines without making any specific frequency or format request.