How realistic is it to expect numerous global regulators who have different national interests, and often different political interests, to harmonize their rules? And even if they achieve harmony, imagine the difficulty of getting an agreement to make any material change. There is something to be said for regulatory disharmony and independent thinking, EXCEPT THAT every regulator insists on regulating each entity that does business in its jurisdiction.  So the path we end up on is…

FINRA also noted the potential uncertainties and risks of investors' relying on hypothetical back-testing results. This should likewise be an area of focus for firms that use such results for advertising purposes.

Whatever one thinks of the FSOC, the manner in which it is funded and the methods by which it operates make it a very odd beast within the government. Significantly, its funding was established so as to make the agency largely immune from Congressional funding cuts for the first years of its operation.

FSOC is a peculiarly partisan agency in that it is governed by procedures that largely assure that all or virtually all of its members come from the President's party. This is in…

Chair Gruenberg's confident assessments add up to an extraordinary assertion of certainty as to the outcome of a crisis, which is inherently a situation whose defining characteristics are panic and uncertainty. Previous bank regulators were equally convinced that the world was under good control, before it turned out to be not so much. Perhaps some degree of greater modesty is now in order.

In the event of a crisis, it will not be obvious that the leaders of a failed bank or…