If all of the swap dealers that are registered currently do a significant amount of business that goes beyond the threshold, then lowering the threshold for dealer registration likely will result in more firms dropping out of the market than deciding to register. In this economic/political climate, very few firms are willing to take on materially greater regulatory burdens in order to do small volumes of business.

Significant rulemaking in this area was inevitable, since meaningful disciplinary actions had been brought against a number of ATSs for failing to operate their systems fairly or protect the confidentiality of their subscribers. That's why it was good to see the SEC produce a rule that reflects a consensus view and that is based, as Commissioner Piwowar pointed out, on concepts of disclosure rather than narrowly defined requirements or broad prohibitions.

Those who are interested in…

Ever since the financial crisis, the FRB has exercised far greater regulatory power than it did previously and, arguably, has done so without close Congressional supervision. Whether it has exercised this power well in the past, and whether it should continue to exercise this power only under light supervision, are two legitimate historical and political questions. Assertions about hypothetical rate policy, however, are fundamentally unprovable. How can the FRB demonstrate that the…

Governor Powell argues for expanded clearing even as he observes that banks are cutting down on providing clearing services (which will make it harder for market participants to hedge and exacerbate concentration risks), and that banks don't want to hold cash for customers who clear (a result that does not seem positive).

Mr. Powell's observation that a very large percentage of plain-vanilla swap trades are now centrally cleared is, for purposes of systemic risk, largely unimportant…