After discussing the risks of central clearing for approximately seventy-five pages, the paper concludes with a passage that begins with these words: "The shift to central clearing has started to mitigate the risks that emerged in non-centrally cleared markets before and during the Great Financial Crisis."

Unfortunately, this conclusion has nothing to do with the rest of the paper. The authors make another statement that is more to the point, though it figures less prominently: "It…

The Act covers financial services provisions in Titles LXXI to LXXXVI (Titles 71-86, for those who neither received a classical education nor care about the Super Bowl).  In some ways, the most interesting statutory amendment that relates to financial services is Title 86, which effectively codifies the longstanding interpretation of exemption from registration for private secondary sales, which generally is known as 4(1-1/2) or, since the JOBS Act, as 4(a)(1-1/2). This longstanding…

In his remarks, the Vice Chair of the Federal Reserve announced that "the Federal Reserve will be developing regulations that would establish minimum margins for securities financing transactions on a marketwide basis. The margins would apply to all market participants, thereby mitigating the risks associated with regulation along institutional lines."

It is not clear under what process, or under what authority, the Federal Reserve will propose and implement these regulations…

Among the difficulties of having a forward-looking discussion about the regulation of global financial markets is that any such discussion necessarily involves making implicit concessions that: (i) at least some of the rule changes are not working out as planned and are having quite negative effects (e.g., increasing market concentration, decreasing liquidity, and separating the American, European and Asian markets) and (ii) rules that are bad for the financial system are often bad for the…