The case illustrates how even a small banking institution can facilitate, whether intentionally or not, significant money transfers of questionable legality.  The failures with which the credit union was charged were similar to those which the federal regulators have warned larger institutions about: not being sufficiently aggressive in filing SARs and not providing sufficient detail in filings.

How much of the letter is devoted to formalities and how much concerns important issues is difficult to say, since some of the proposed rules are not significant to market participants; e.g. the rules on orderly liquidation and shareholder reports. At least three new Commissioners will be joining the SEC in the next few months. Surely, it is appropriate to allow those Commissioners to decide for themselves whether to proceed with the swap dealer rules as proposed or to amend them.…

Broker-dealers and exchanges are locked in a perpetual battle over the fees that exchanges are permitted to impose.

A number of the systemic threats in the reports are due in large part to government intervention in the markets; e.g., the high debt levels that result from extremely low interest rates, and the increase in size of very large banks, which arguably is exacerbated by the costs of regulation that weigh most heavily on smaller firms.

The most notable threat acknowledged by the OFR is that which is created by central counterparties: "We are concerned that, although clearing swaps…