SEC conveniently left enough well designed "loopholes"

so that banks and trading firms can bypass such reporting requirement. A clue, if you separate TRS from oil contracts with layerings, the rule is by passed.

The point is, if the government want to help the controlling groupls behind it (oil interest groups), the government will always leave enough loopholes. But in public, they will say that "now SEC is going to require xxxxxxx....", just to fool those who don't understand.