> 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.