On December 8, 2020, the U.S. Commodity Futures Trading Commission (“CFTC” or the “Commission”) held an open meeting at which it voted 4-1 (with Commissioner Rostin Behnam dissenting) to adopt a final rule, applicable to designated contract markets (“DCMs”), addressing electronic trading risk principles (the “Final Rule”). The Final Rule, which substantially tracks the proposed rule promulgated on July 15, 2020 (the “Proposed Rule”), takes a principles-based approach to monitoring risks inherent in electronic trading, and is designed to provide DCMs with the flexibility to tailor the rules and pre-trade risk controls for market participants subject to each DCM’s respective jurisdiction. The CFTC believes that this approach provides DCMs with the requisite flexibility to implement rules and procedures appropriate for their markets and to adapt and evolve with changing technologies and markets.