This article examines the regulation of risk-backed securities under the Co
mmodities Exchange Act (the CEA) as enforced by the Commodity Futures Tradi
ng Commission (the CFTC). The author concludes that regulatory reform for d
erivatives is necessary in order to provide greater clarify to market parti
cipants, bur cautions that such reform must be flexible enough to allow for
expansion and innovation in this changing market.