On July 23rd, CFTC Commissioner Scott O'Malia testified before a House agriculture subcommittee. O'Malia discussed the agency's Dodd-Frank rulemaking in general, and its use of no-action letters concerning the Act's swaps provisions in particular. He voiced strong disapproval for the agency's repeated use of no-action letters, believing that they violate the Administrative Procedures Act. O'Malia also expressed concern over the Enforcement Division's use of a summary procedures process to institute enforcement actions. In an unusual move, O'Malia asked Congress to investigate these matters. O'Malia Remarks.