The bifurcation of the regulation of transactions in Treasuries between the SEC and the CFTC is harmful. It (i) diminishes regulatory transparency (by dividing oversight) and (ii) raises costs by making it more expensive to effect hedge transactions when neither regulatory scheme takes account of the risk reducing effect of transactions under the other regulatory scheme.  

Perhaps it appears "safer" to consumers when regulators propose to increase regulation (and never to lessen it). But that is the wrong approach. The adoption of rules is inherently a process of prediction and those predictions may turn out to be wrong. Rules may become outdated or not have their intended effect or may be more expensive to implement than projected. Regulators should evaluate existing rules on an ongoing basis, just as they consider new rules.  

Perhaps it is time to revisit the notion that there should be a presumption of the delivery of paper documents.

Broker-dealers should be aware that contingent liabilities, such as guarantees, are treated as liabilities for net capital purposes. Accordingly, broker-dealers should generally not provide any guarantees except those that are adequately collateralized by margin securities.