With so many letters to work with, and the legal authority to change the terms, the FRB could have come up with a more memorable acronym than ORSOM. How about this one: "At Most 10"?

A = Access, T = Transparency, M = Market Support, O = Organization, S = Settlement, T = Technology, I = Information and O = Operations. I recognize that substituting 1O for IO is playing fast and loose with the language, but certainly, it would be within the FRB's authority to do so.…

By these remarks, Chair Massad joins several other regulators in acknowledging the substantial risks created by central clearing, including the huge concentration of risk to the financial system that results from clearing. In light of these belated admissions, and in recognition of Chair Massad’s (et.al.,) concerns over "unintended consequences" (see related news stories below), it would be prudent for the CFTC to declare a moratorium on any further imposition of a mandatory clearing…

Contrary to the assertion in Rep. Cummings' letter that the SEC does not delegate tasks to other entities, numerous tasks, in fact, are delegated by the SEC to FINRA and the other self-regulatory organizations, and many of those tasks are far more significant than those set out in Chair White's proposal. As a practical matter, the SEC delegates the entire task of registering broker-dealers and qualifying their employees to FINRA. Further, the CFTC delegates the entire task of registering…

While Director Berner identifies his role as being that of a mere aggregator of information, and not as a policy maker, the information that he collects is largely determined by those who have certain policy views on what creates risk to the financial system. Thus, he is concerned with, for example, securities financing transactions, capital levels at banks, and the operation of central clearing houses.

Mr. Berner’s remarks also suggest that this data collection may not identify the…