The decrease in the number of FCMs is notable, even in a period of financial industry consolidation. Dodd-Frank Act was supposedly going to increase competition in the derivatives markets; instead, it has increased concentration. It would be a useful exercise for the regulators to review every prediction by the proponents of Dodd-Frank to measure how many; i.e, few, of those predictions were realized. I would not be surprised if the success rate did not reach the Mendoza line. …

But you can't make him sign. No one knows how much take-up there will be of the done away structure.  

The regulators are repeating with respect to election contracts the same mistake they made with respect to digital assets. Rather than admit the need for legislative action, and press for it, the CFTC is pushing forward as if there is no uncertainty.

It's just not obvious that the Dodd-Frank Congress intended to do away with State gambling laws. It is also apparent that the courts are significantly divided on the issue. Further, there are legitimate public policy…

The big question will be, "When is it appropriate for a broker-dealer to ignore or trade through a better bid or offer?" For example, firms may reasonably determine that the information cost of trading with a small offer, or the operational hassle, makes it not worthwhile. It will be interesting to see what impact this may have on odd-lot trading.

Similarly, firms may decide that it is not useful to maintain connectivity to a small exchange with limited trading…