If the CFPB's poor financial reporting record doesn’t seem ironic enough, consider this: the statute that authorizes the CFPB does not give Congress direct control over the CFPB's budget.

That all of this data is materially useful, or worth the cost of its collection, is neither obvious nor apparent. How can the expense of collecting information on the "life cycle" of a swap be justified in terms of helping analysts understand the buildup of risk in a system – especially when point-in-time data on outstanding notional amounts can be harvested far more cheaply?

In Mr. Cook, FINRA has found a strong replacement for Mr. Ketchum.  Mr. Cook's leadership will reflect significant private and governmental experience.

The differing viewpoints of CFTC Commissioners Giancarlo and Bowen serve to illustrate three separate, recurring issues in financial regulation: (i) the desirability of speed vs. care; (ii) the demands of the government for information; and (iii) the significance of the debate itself.

As to the issue of speed vs. care, both Commissioners agree on the desirability of formulating rules to govern automated trading. The argument that Commissioner Bowen advances seems fairly weak; i.e…