The SEC is applying common sense to the scope of the clearing mandate; i.e., as to the exclusion from the mandate of repos that may include U.S. Governments. Nonetheless, the ultimate economic impact of the mandate on the costs of funding U.S. Government debt is inherently uncertain. Given that uncertainty, it seems prudent for the SEC to exclude non-U.S. transactions from the mandate; or at least delay the application until the market has absorbed the impact of imposing the…

Commissioner Crenshaw's statement that regulatory harmonization should "never be an end in itself" should be challenged. While it may not be the only end, harmonization should be a significant goal. It is very important. Duplicative and inconsistent regulations are a tax on the market, and indirectly a tax on users of the markets. Or to put it in the language of the SEC's three-part mission, as quoted by Commissioner Crenshaw, harmonization serves the goals for developing efficient market…

Commissioner Peirce's thoughtful, disciplined approach to regulation, always respectful of the bounds of the law and of governmental (and human) capacity, are a model for how it should be done.   

On a personal note, I have long been a fan, and, notwithstanding what may make her happier, I hope that she will not take up farming, but will stay involved with the financial world and provide commentary and insight, which was always delivered with great humor, and with more…

In order for the central clearing mandate to be successful, it was essential that the clearing firms receive favorable capital treatment.