The extension is essentially a formality, since there are no SEC rules in place to regulate security-based swap dealers.

This proposal (contained in MSRB Reg. Notice 16-02) and the proposal to shorten the securities settlement cycle (contained in MSRB Reg. Notice 15-22), along with related requirements for margin to be posted on To-Be-Announced securities, reflect regulators' ongoing drive to decrease settlement risk in the securities markets.

If ever a finding came under the heading of "as surely as the sun rises in the east," it is that Dodd-Frank has increased regulatory costs. That said, based on the structure of this report, for reasons that were not the intentions of the GAO, the costs of Dodd-Frank are significantly understated. As a starting matter, the report deals with the costs imposed only on a very small subset of financial institutions. Secondly, the report covers only those rules whose costs to the economy are…

The implicit message of the staff's letter is that the staff (not surprisingly) prefers electronic filings. One question that this raises (not actually directly related to this letter) is whether the SEC should as a rule allow electronic delivery by broker-dealers of all documents to customers (and not just to regulators). As this letter points out, electronic delivery is in fact faster and more certain. The existing regulatory preference for paper delivery of documents to customers (absent…