It seems a bit odd that the United States appears to be so eager to share financial information with non-U.S. regulators. While there are certain reasons to share selectively, there are also reasons why it may be better not to share broadly.

To expand on Commissioner Giancarlo's remarks about government-created "risk": governments create problems for the markets partly because government action can take place on such a grand scale, so suddenly and with so little regard for ordinary economic considerations. One example that is relevant to today's news, regarding increased capital requirements for forex transactions, is the action of the Swiss government with respect to its currency, which precipitated the recent dislocation in…

The extent to which it is economically feasible to mandate the central clearing of swaps has been vastly oversold. While it is doable (and has been done) for certain rate and currency swaps and a limited number of index swaps, it is largely impractical for most, and perhaps all, other underlying instruments.

The bottom line is this: in the event of a successful cyber attack, not only is the victimized firm's business at risk, but the officers of the firm also may be charged with supervisory failure if they are deemed to have failed to install adequate computer defenses. While there is no question that firms should install defenses against cyber attacks, it is worrisome that individuals and firms can be charged with regulatory failure in the absence of any standards for adequate supervision,…