There may be some value to firms in reviewing the recordkeeping requirements applicable to the government agencies. Firms might consider whether they would meet these standards or whether they have missed any of the issues raised in the GAO report.

IOSCO's study is really about the proposed LIBRA coin; that is, a digital asset supported by a reserve of assets determined to be relatively safe, such as the type of assets that are typically owned by money market funds. (.) IOSCO proposes that many of the same regulations that apply to money market funds would apply to a stablecoin backed by money market fund assets. However, LIBRA was a fundamentally flawed product. Among other things, as designed, LIBRA would have been subject to…

The FRB should consider expanding access to the discount window to broker-dealers other than primary dealers. Going forward, the FRB should consider formalizing the procedures by which it is opening the discount window to selected broker-dealers. That some broker-dealers, but not all, have access to the discount window is competitively unfair and puts added economic stress on those dealers not having access to the window. It is not inherently the case that only "better / safer"…

Reconsidering aspects of CAT in light of the cybersecurity issues raised by the coronavirus is a good thing. In general, the regulators should give more consideration to whether the cybersecurity risks of CAT are worth the regulatory benefits. At least as currently contemplated, a cyber break of the CAT data would not only be damaging to the financial markets, it would undermine any confidence in the regulators. See also .

Sometimes it is true that what you don't know (or, at least,…