In his remarks, the Vice Chair of the Federal Reserve announced that "the Federal Reserve will be developing regulations that would establish minimum margins for securities financing transactions on a marketwide basis. The margins would apply to all market participants, thereby mitigating the risks associated with regulation along institutional lines."

It is not clear under what process, or under what authority, the Federal Reserve will propose and implement these regulations…

Among the difficulties of having a forward-looking discussion about the regulation of global financial markets is that any such discussion necessarily involves making implicit concessions that: (i) at least some of the rule changes are not working out as planned and are having quite negative effects (e.g., increasing market concentration, decreasing liquidity, and separating the American, European and Asian markets) and (ii) rules that are bad for the financial system are often bad for the…

As numerous as SIFMA's comments are on FINRA's proposal, the problems with the proposal appear to be even more intractable and fundamental than addressed here. A self-regulatory organization, such as FINRA, simply should not put its members under any obligation, or seeming obligation, to violate the law by refusing to disburse money in accordance with instructions that are legally binding. This is not to deny the potential existence of a real problem concerning the need to protect senior…

The regulators were uniformly upbeat in describing their efforts at reducing the burdens imposed by regulations on community banks. It would be interesting to conduct a poll of the community banks to see whether they are equally upbeat upon this subject.