Ms. Walter served with distinction as SEC Commissioner. During the latter portion of her time at the SEC, she focused on the debt markets, particularly the municipal securities markets, as well as on corporate financial disclosures. See, e.g., ; and .

Mr. Tuckman is the author of a terrific piece explaining derivatives, ", which is published (among other places) on the Cabinet.

Much of the complaint is predicated on the assertion that, were it not for industry collusion, it is inevitable that the securities lending markets would be centrally cleared. In reality, central clearing is far less attractive than the plaintiffs assume. One need only look at the swaps market where, despite all of the initial regulatory enthusiasm, central clearing has not advanced beyond the most plain-vanilla products. Similarly, the notion that central clearing eliminates credit risk is…

Maintaining the CAB rule set is largely a waste of regulatory resources. Rather than adopting, and now having to maintain the CAB rules FINRA should have amended the existing rules to make clear that certain requirements were irrelevant to firms doing a very limited business.