[JohnHaugeland]

> I read the CFTC revocation letter, they do not justify anything unless you have a very loose definition of justify

The CFTC letter says "we made an agreement eight years ago and you never honored it."

If you want the justification, read the original agreement, not the "you broke your promise, no more special privileges for you" notice.

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> their letter says "we had X exceptions, we say you failed" That is not justification

That's correct. You looked in the wrong place. Punishment for failing to honor an agreement is not, generally, where people explain the purpose of the agreement.

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> Nothing in the 2 page note provides any actual justification.

That's correct. You looked in the wrong place.

[phpisthebest]

The original no-action letter offers no justification either, just a series of edicts by the regulators and a comparison to a previous small market.

They start from the assumption that their regulations are good, correct and need, they offer no justifications on why the limits or guidelines are imposed or why it should be regulated at all.

Nothing in any of the letters has anything resembling justification, at best the revocation letter is circular logic citing the no action letter but in neither is anything justified

[JohnHaugeland]

> The original no-action letter offers no justification either,

This is also not the correct place to look.

The original no-action letter is after the discussion was had, and everyone was already on the same page, so of course that wouldn't be the place where they explained their premise.

Twice in a row you've looked in a place nobody would ever put it, and said "well it's not there, so I guess nobody ever explained it."

This conversation holds no value to me. If you choose to be unable to find this wholly documented thing, so be it.

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> Nothing in any of the letters has anything resembling justification

You've only looked in two places for an explanation, and they're both after the decision, where an explanation would never be.

Once this could be excused as a simple mistake, but you circled back around and did it again with a bright light already shone on the mistake.

Good luck to you.