It is unclear why anyone would elect to register as a Funding Portal: a lot of rules without material opportunity for profit.  

The NYSE's most interesting proposal was for stop-loss orders (which the NYSE acknowledged come largely from retail investors) not to be accepted during times of market downturn. This effectively would prevent retail investors (who cannot watch the markets interminably) from selling automatically when institutional investors (who always watch the markets) sell deliberately. It is reasonable to argue that this would protect retail investors by limiting their ability to cause, or sell…

Kudos to the professors for providing a fulsome analysis of the CFTC's assertions. Anyone who possesses common sense and some degree of knowledge of the way in which markets work (including their unpredictability) should have recognized the absurdity of the CFTC and the Department of Justice's assertion that Mr. Sarao caused the flash crash. See, e.g., ." Streetwise Professor Pirrong also deserves recognition for pointing out how far-fetched the CFTC's…

The OFR's findings on central clearing seem noncommittal. According to the OFR, a central counterparty reduces risk as long as it does not default. Bear in mind, however, that a central counterparty "is a single point of vulnerability for failure."