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SEC Commissioner Kara M. Stein delivered remarks at the Consumer Federation of America's 27th Annual Financial Services Conference. She focused on disclosure, aligning interests of market participants and accountability. Commissioner Stein explained that disclosures are only an effective tool only if they can provide the investor with the information needed to make "informed decisions about the future." Commissioner Stein recognized that there are "disparate levels of investor capacity in the marketplace," and stated that the SEC's "one-size-fits-all approach" falls short of providing

U.S. Treasury Deputy Secretary Sarah Bloom Raskin spoke at the Texas Bankers' Association Executive Leadership Cybersecurity Conference, providing a "roadmap" for CEOs of information regarding cybersecurity and cyberattacks. Ms. Raskin provided a series of questions and answers regarding steps CEOs and their firms can take before and after a cyberattack. In her first set of recommendations, Ms. Raskin focused on "baseline protection," or the policies and controls that firms can adopt to "prevent penetration of their networks and systems" and minimize damage. Ms. Raskin stated that

MFA submitted comments to the CFTC outlining concerns and recommendations for the CFTC's proposed rulemaking on margin requirements for uncleared swaps for swap dealers and major swap participants. MFA's letter to the CFTC was similar to the letter recently sent to U.S. prudential regulators regarding the re-proposal of uncleared margin and capital requirements for prudentially regulated covered swap entities. The letter to the CFTC also responded to the CFTC's advance notice of proposed rulemaking on three alternative approaches to the cross-border application of its uncleared margin

Governor Lael Brainard of the Board of Governors of the Federal Reserve System ("FRB") delivered remarks at the Hutchins Center on Fiscal and Monetary Policy regarding the FRB's ongoing work to safeguard financial stability. Recognizing that the FRB is primarily a supervisor of banks and bank holding companies with limited access to market data regarding the activities of non-bank financial intermediaries, Governor Brainard stressed the importance for the FRB to utilize the tools under its authority to preserve the structural resilience of the largest and most complex financial institutions

Bob Zwirb Commentary by Bob Zwirb

Experts at NERA Economic Consulting issued a quantitative impact study to analyze the potential costs and benefits of the CFTC's proposed rule on initial and variation margin requirements of uncleared swaps for swap dealers and major swap participants. According to the NERA study: the aggregate incremental opportunity costs of the proposed margin requirements in normal markets are substantial, estimated at $411 million per year; several aspects of the proposed rule are pro-cyclical and thus will likely increase systemic risks rather than mitigate them, including monthly recalibration of