On March 3rd, the CFTC published for comment a proposed interpretive order regarding the three statutory disruptive practices set forth in new Section 4c(a)(5) of the Commodity Exchange Act, as amended by the Dodd-Frank Act. New Section 4c(a)(5) makes it unlawful for any person to engage in any trading, practice, or conduct on or subject to the rules of a registered entity that: violates bids or offers; demonstrates intentional or reckless disregard for the orderly execution of transactions during the closing period; is of the character of, or is commonly known to the trade as, "spoofing" (bidding or offering with the intent to cancel the bid or offer before execution). Comments should be submitted within 60 days after publication in the Federal Register, which is expected during the week of March 7. Proposed Interpretive Guidance.