If adopted, this proposal will make it more difficult for large financial institutions to hire top talent. The requirement of a long deferral period and clawback provisions (subject to an uncertain legal standard for up to seven years) may make it more attractive for individuals to pursue work at an unregulated entity or at least a smaller institution. It is far from obvious that it is good public policy to make it more expensive for larger financial…

Ready, fire, aim. This study is an unintentional critique of how Dodd-Frank and its related rulemaking has played out. First, mandate a change. Then, conduct a study to determine that, even if the prior system was somewhat flawed, the mandated alternatives are arguably worse.  

There are any number of provisions of Dodd-Frank as to which one could arguably make the same point. Mandated central clearing remains the poster child of the bunch. First, mandate…

Senator Warren's questions may be reasonable, but the manner in which she asks them is suspect. Might her demand letter be interpreted as a form of political intimidation?

According to FSOC, its review of asset managers focuses on "risks to financial stability rather than investment risk," which the report describes as a normal and necessary part of market functioning. By contrast, FSOC maintains, financial stability risk arises because the activities of individual market participants may affect the system more broadly, particularly during times of market stress.

Regardless of FSOC's distinction between the two kinds of risk, in the actual world, there…