The CFTC's review of these submissions will now force the Commission and possibly the prudential regulators to confront the reality that central clearing, which is often touted as the solution to risk, is itself quite risky. The question, then, becomes this: do the regulators (i) reject some or all of these submissions and admit that central clearing was oversold as a regulatory tool or (ii) accept all of the submissions and open the door to even more submissions on less liquid products?

To what extent will prudential regulators and the SEC act, by choice or compulsion, in a manner that is consistent with the FSB's recommendations?

Overlapping, duplicative and confusing regulations imposed by multiple regulators on exactly the same activity is bad public policy.

In light of Mr. Osnato's warning, all firms should make it a priority to conduct an audit of their customer protection rule procedures, including their calculation methodology and procedures for segregating securities.