This nonpolitical regulatory initiative has the potential to produce very material benefits for both regulated entities and regulators. As it is, the CFTC (like other regulators) requires that firms produce tremendous amounts of data that are both difficult to provide and utterly worthless. Ideally, firms will take the time to comment and other regulators will follow suit in undertaking a review of their own requirements.

A material portion of the "risk" that banks face, according to the report, is regulatory risk. The Comptroller's remark that "[m]ultiple new or amended regulations are posing challenges" to banks and the financial system also echoes the comment made by the SEC's Investor Advocate in his recent report to Congress that he would "encourage Congress to consider giving the [SEC] a respite from statutory mandates" (at 3). It is clear that the very rate and extent of regulatory change has itself…

Given the volatility of bitcoin, is it good public policy to encourage central clearing of the product? What would be the effect on pricing or on market participants if the DCO suddenly were to double or triple initial margin requirements?

Governor Powell's view seems to echo Peter Wallison's dissenting opinion in the (at page 444). Indeed, a credit to Mr. Wallison, a Fellow at the American Enterprise Institute and a former minority member of the Commission might be in order. In any case, there is no doubt that the change in Administration has resulted in a moderate amount of rethinking of the supposed benefits of Dodd-Frank and prior regulatory policy generally, even by those who were previously complete champions.…