For other apparent "good news" from FDIC Chair Gruenberg, see, e.g., 

Mr. Gruenberg states accurately that some measures of liquidity have in fact steadied or improved. He is, no doubt, aware that some measures of liquidity look materially worse. The question of which measures of liquidity are "better" might be the subject of some debate, but what should not be debated is the reality that the numbers are mixed. Anyone who is interested in a more…

Perhaps the questions that Congress should ask are these: Why are so many states, cities and municipal entities approaching insolvency? What factors drive governmental entities to run at unsustainable deficits? These are not trivial questions, since it is reasonable to expect that numerous governmental entities will go bust in the coming years. To borrow a phrase from the pols, "investors will not regain confidence in [governmental] debt" until the governments themselves prove they can…

This case sends a powerful message to service providers and other entities that are not directly regulated by the SEC: they still may be subject to sanction whenever their misconduct or negligence allows another entity to violate a requirement to which the other entity is subject directly.

FINRA's failure to respond to SIFMA's comments in any meaningful way is disappointing, as is the SEC's approval of the rule change despite the absence of any such response. SIFMA's most significant comments addressed the timing of margin delivery and not the substance of the margin requirements; i.e., SIFMA merely asked for the timing of margin delivery under the TBA rules to be conformed to the timing of margin delivery under the rest of Rule 4210.

(Note: Cadwalader represented…