IOSCO's study is really about the proposed LIBRA coin; that is, a digital asset supported by a reserve of assets determined to be relatively safe, such as the type of assets that are typically owned by money market funds. (.) IOSCO proposes that many of the same regulations that apply to money market funds would apply to a stablecoin backed by money market fund assets. However, LIBRA was a fundamentally flawed product. Among other things, as designed, LIBRA would have been subject to…

The FRB should consider expanding access to the discount window to broker-dealers other than primary dealers. Going forward, the FRB should consider formalizing the procedures by which it is opening the discount window to selected broker-dealers. That some broker-dealers, but not all, have access to the discount window is competitively unfair and puts added economic stress on those dealers not having access to the window. It is not inherently the case that only "better / safer"…

Reconsidering aspects of CAT in light of the cybersecurity issues raised by the coronavirus is a good thing. In general, the regulators should give more consideration to whether the cybersecurity risks of CAT are worth the regulatory benefits. At least as currently contemplated, a cyber break of the CAT data would not only be damaging to the financial markets, it would undermine any confidence in the regulators. See also .

Sometimes it is true that what you don't know (or, at least,…

On a substantive basis, this rule proposal may be seen as a non-event. Broker-dealers must adhere to the rules of both the SEC and FINRA. Where the two regulators have adopted requirements as to the same topic; e.g., suitability, and the SEC's rules are tougher, the FINRA rules are effectively irrelevant. This FINRA rule proposal simply recognizes that legal reality, and is thus of no real substantive effect.

From a process standpoint, however, this rule proposal raises a more…