Concurring Statement of Commissioner Dan M. Berkovitz Regarding Rule Amending CFTC Division and Office References in Connection with Staff Realignment
December 08, 2020
I concur in issuing the final rule that revises certain provisions of the Commission’s regulations to reflect recent changes to the CFTC’s administrative structure (Final Rule). The Final Rule changes dozens of references to various CFTC divisions and offices and the respective directors thereof, as well as certain addresses of CFTC offices, in accordance with the realignment.
The realignment was undertaken at the Chairman’s direction. Approval of the reorganization itself is not the subject of the Final Rule, and such approval has not otherwise been requested of the Commission. Rather, the Final Rule is necessary to change delegation authorities and reference the appropriate officials or offices for filings, notices, and other correspondence. As a Commissioner, I have a ministerial duty to maintain the accuracy of our regulations and therefore I concur in adoption of the Final Rule.
 Accordingly, my approval of the Final Rule should not be viewed as approval of the reorganization itself.