This rule is, undoubtedly, motivated by virtuous intentions. That does not necessarily mean that it will have a good result or will be experienced as helpful by its intended beneficiaries. One can reasonably guess that an effect of the rule will be to drive up the cost of payday loans or effectively to prohibit a good number of such loans. That might have a good result, akin to discouraging people from buying cigarettes. Or it might have a bad result, making it impossible for those who…

As was the case with the Madoff fraud, investors who thought that their money was paid out could be vulnerable to a clawback.

The realization of the "importance" of industry participation in the FSOC designation process is welcome. When FSOC designated MetLife as being systemically important, it generally ignored the views of the FSOC member with insurance industry experience. See See also .

Historically, FX trading has not been subject to the same level of comprehensive regulation as have been the securities and futures markets. That is obviously changing with swaps regulation and with the publication of best practices standards for the FX market. See . Every institution that trades in FX should review their procedures, compare those procedures against comparable procedures in other markets, and see whether the differences are justified by the markets or whether they are a…