The Commissioner of the Commodity Futures Trading Commission (“CFTC”), Scott O’Malia, argued that the Volcker Rule is too complex, and may fall short of providing an appropriate foundation for a rigorous and reliable rulemaking process. Mr O’Malia suggested that the CFTC and other agencies will have to re-propose the rule in order to combat complexity and clarify roles between regulators. He also expressed reservations about the compliance programme mandated by the proposed rule, as well as the viability of enforcement, and the extraterritorial implications. The Volcker Rule is currently open to consultation with four agencies.