Streetwise Professor

July 6, 2017

Once Upon a Time in Annapolis

Filed under: History,Military — The Professor @ 7:20 pm

Please indulge me with a trip down memory lane. Forty years ago today I was inducted as a Plebe at the United States Naval Academy. I’m sure all you all* find that hard to believe. No, not that I went to Navy–the 40 years part 😉

Plebe Summer was a grind, but I can’t say that it was that difficult. There were in fact some high points. I can still get some yucks (not just from myself, but from others) with stories from that summer. Most related to my battles with authoritah! As I’ve often said–including under oath (when some attorney digging for dirt during a deposition asks why I left the Academy–but that’s getting ahead of the story)–Navy is where I learned that I had issues with authority, and that I was a libertarian rather than a conservative. During Plebe Summer I expected a lot of Mickey Mouse, and got it. But I was operating under the false belief that after the ritual was over, things would get serious and the Mickey Mouse would end. Wrong!

I soon learned that the BS was 24/7, and that standing out in any way attracted unwanted attention and harassment from some pretty twisted people. And I do mean twisted. Perhaps my experience was an outlier, but the upperclassman (along with his roommate) who took a special dislike to me was really twisted. How twisted? Killing his entire family in their sleep twisted. I really didn’t want to spend my 20s (and perhaps beyond) having to be subordinate to the likes of them.

During my years at Navy I also became sufficiently confident in my ability that I knew I could make it in many different careers and didn’t need the structure and security of the Navy. My dad was aghast when he learned (from my former high school history teacher, in whom I’d confided) that I was thinking of leaving. He was a classic manager/executive guy, and sat me down for a talk when I was home on spring break leave. In the 21st century, I’m sure he would have prepared a PowerPoint presentation. In that analog age, he instead prepared flip charts laying out the case for staying at Navy. This involved going into nuke power. Unfortunately, he gave this presentation the week after Three Mile Island blew. Really. Talk about your awkward timing!

I told him “Dad, I really appreciate the thought and effort, but that’s just not me.” As a compromise I agreed to attend the summer professional training (PROTRAMID) which involved spending a week at the surface, submarine, air, and Marine training facilities, and to defer making a decision until afterwards. But as soon as I got back to Annapolis, I prepared a resignation letter (a copy of which I found when cleaning out my mom’s house last month).

The usual routine was for a resigning Mid to have an exit interview with the Deputy Commandant. I did, but then I had one with the Commandant, and finally, the Superintendent (which almost never happens). The Supe was a bad-ass: Medal of Honor winner VADM William P. Lawrence. Admiral Lawrence asked me if there was anything he could do to convince me to stay. I cheekily said “guarantee a slot in Naval Intelligence and I will consider it.” (I was really not interested in boats, especially the kind that went underwater, and didn’t have the eyes to fly.) He said that was not legally possible, so I said, “then there is nothing you can do.” We shook hands, then I saluted, did an about face, and left.

Shortly thereafter, I went from alpha (the Academy) to omega (the University of Chicago). Many serendipitous twists and turns and 38 years later, and here I am.

A high point in that saga came about 25 years after I left Navy. My dad said to me one Christmas: “I thought you were making a big mistake, but you made the right choice.” That was good to hear, and I know he was right–the really important thing was that he knew it was right. It was the right choice to go, and it was the right choice to leave. When I look back–which I do seldom, and mainly on days like this–I do so with no regrets, and with pride. Pride at having gone there, but mainly pride at having no reason to regret deciding to leave.

* This is a Texan phrasing that I have adopted because it is so much more precise than “you”.

SWP Acid Flashback, CCP Edition

Filed under: Clearing,Derivatives,Economics,Financial crisis,Regulation — The Professor @ 6:09 pm

Sometimes reading current news about clearing specifically and post-crisis regulation generally triggers acid flashbacks to old blog posts. Like this one (from 2010!):

[Gensler’s] latest gurgling appears on the oped page of today’s WSJ.  It starts with a non-sequitur, and careens downhill from there.  Gensler tells a story about his role in the LTCM situation, and then claims that to prevent a recurrence, or a repeat of AIG, it is necessary to reduce the “cancerous interconnections” (Jeremiah Recycled Bad Metaphor Alert!) in the financial system by, you guessed it, mandatory clearing.

Look.  This is very basic.  Do I have to repeat it?  CLEARING DOES NOT ELIMINATE INTERCONNECTIONS AMONG FINANCIAL INSTITUTIONS.  At most, it reconfigures the topology of the network of interconnections.  Anyone who argues otherwise is not competent to weigh in on the subject, let alone to have regulatory responsibility over a vastly expanded clearing system.  At most you can argue that the interconnections in a cleared system are better in some ways than the interconnections in the current OTC structure.  But Gensler doesn’t do that.   He just makes unsupported assertion after unsupported assertion.

Jeremiah’s latest gurgling appears on the oped page of today’s WSJ.  It starts with a non-sequitur, and careens downhill from there.  Gensler tells a story about his role in the LTCM situation, and then claims that to prevent a recurrence, or a repeat of AIG, it is necessary to reduce the “cancerous interconnections” (Jeremiah Recycled Bad Metaphor Alert!) in the financial system by, you guessed it, mandatory clearing. Look.  This is very basic.  Do I have to repeat it?  CLEARING DOES NOT ELIMINATE INTERCONNECTIONS AMONG FINANCIAL INSTITUTIONS.  At most, it reconfigures the topology of the network of interconnections.  Anyone who argues otherwise is not competent to weigh in on the subject, let alone to have regulatory responsibility over a vastly expanded clearing system.  At most you can argue that the interconnections in a cleared system are better in some ways than the interconnections in the current OTC structure.  But Gensler doesn’t do that.   He just makes unsupported assertion after unsupported assertion.

So what triggered this flashback? This recent FSB (no! not Putin!)/BIS/IOSCO report on . . . wait for it . . . interdependencies in clearing. As summarized by Reuters:

The Financial Stability Board, the Committee on Payments and Market Infrastructures, the International Organization of Securities Commissioners and the Basel Committee on Banking Supervision, also raised new concerns around the interdependency of CCPs, which have become crucial financial infrastructures as a result of post-crisis reforms that forced much of the US$483trn over-the-counter derivatives market into central clearing.

In a study of 26 CCPs across 15 jurisdictions, the committees found that many clearinghouses maintain relationships with the same financial entities.

Concentration is high with 88% of financial resources, including initial margin and default funds, sitting in just 10 CCPs. Of the 307 clearing members included in the analysis, the largest 20 accounted for 75% of financial resources provided to CCPs.

More than 80% of the CCPs surveyed were exposed to at least 10 global systemically important financial institutions, the study showed.

In an analysis of the contagion effect of clearing member defaults, the study found that more than half of surveyed CCPs would suffer a default of at least two clearing members as a result of two clearing member defaults at another CCP.

This suggests a high degree of interconnectedness among the central clearing system’s largest and most significant clearing members,” the committees said in their analysis.

To reiterate: as I said in 2010 (and the blog post echoed remarks that I made at ISDA’s General Meeting in San Fransisco shortly before I wrote the post), clearing just reconfigures the topology of the network. It does not eliminate “cancerous interconnections”. It merely re-jiggers the connections.

Look at some of the network charts in the FSB/BIS/IOSCO report. They are pretty much indistinguishable from the sccaaarrry charts of interdependencies in OTC derivatives that were bruited about to scare the chillin into supporting clearing and collateral mandates.

The concentration of clearing members is particularly concerning. The report does not mention it, but this concentration creates other major headaches, such as the difficulties of porting positions if a big clearing member (or two) defaults. And the difficulties this concentration would produce in trying to auction off or hedge the positions of the big clearing firms.

Further, the report understates the degree of interconnections, and in fact ignores some of the most dangerous ones. It looks only at direct connections, but the indirect connections are probably more . . . what’s the word I’m looking for? . . . cancerous–yeah, that’s it. CCPs are deeply embedded in the liquidity supply and credit network, which connects all major (and most minor) players in the market. Market shocks that cause big price changes in turn cause big variation margin calls that reverberate throughout the entire financial system. Given the tight coupling of the liquidity system generally, and the particularly tight coupling of the margining mechanism specifically, this form of interconnection–not considered in the report–is most laden with systemic ramifications. As I’ve said ad nauseum: the connections that are intended to prevent CCPs from failing are exactly the ones that pose the greatest threat to the entire system.

To flash back to another of my past writings: this recent report, when compared to what Gensler said in 2010 (and others, notably Timmy!, were singing from the same hymnal), shows that clearing and collateral mandates were a bill of goods. These mandates were sold on the basis of lies large and small. And the biggest lie–and I said so at the time–was that clearing would reduce the interconnectivity of the financial system. So the FSB/BIS/IOSCO have called bullshit on Gary Gensler. Unfortunately, seven years too late.

 

The Qatar LNG Expansion Announcement: Vaporware Meets LNG?

Filed under: Commodities,Economics,Energy,Politics — The Professor @ 4:04 pm

Qatar sent shock waves through the LNG market by announcing plans to increase output by 30 percent. Although large energy firms (including Rex Tillerson’s old outfit) expressed interest in working with Qatar on this, color me skeptical.

I can think of two other explanations for the announcement, particularly at this time.

The first is that this may be akin to a vaporware announcement. Back in the day, it was common for software firms to announce a new product or a big update of an existing product in order to try to deter others from entering that market. If entry in fact did not occur, the product announced with such fanfare would never appear. Similar to this strategy, I think it is very plausible that Qatar is trying to deter entry or expansion by North American, Australian, and African producers by threatening to add a big slug of capacity in a few years. Perhaps the developers won’t be scared off, but their bankers may be.

The surge in LNG capacity around the world has severely undercut Qatar’s competitive position, and forced it to make contractual concessions. It also threatens to erode prices for a considerable period. Even more entry would exacerbate these problems. This gives Qatar a strong incentive to try to scare off some of that capacity, and a vaporware strategy is worth a try in order to achieve that.

The second is based on the current set-to between Qatar and the Saudis and the rest of the GCC. They are all but blockading Qatar, and have made demands that bring to mind Austria-Hungary’s demands against Serbia in July, 1914: the ultimatum is designed to be rejected to give a pretext for escalation. Qatar needs to demonstrate that it is immune to the pressure. An announcement of grandiose expansion plans is a good way to signal that it is immune to pressure and not only plans to continue business as usual, but to go further. In a part of the world where showing weakness is an invitation for the wolves to pounce, putting on a bold front is almost a necessity when the wolves are already circling.

So we’ll see where this goes. But I think there’s a good likelihood that this is a big bluff.

July 4, 2017

Sunlight is the Best Disinfectant: If the Light of Day Scares You, You May Be a Germ

Filed under: Climate Change,History,Politics — The Professor @ 10:30 am

The Climate Change Mafia is threatening to go to the mattresses over EPA director Scott Pruitt’s plans to hold a “red team/blue team” exercise to evaluate climate science. Given the billions the US lavishes on this research, such a review is a salutary thing: but perhaps because it threatens said billions, the Mafia is going nuts:

The idea has been derided by activists and scientists who say it’s “dangerous” to elevate dissenting voices who disagree with them on global warming.

“Such calls for special teams of investigators are not about honest scientific debate,” wrote climate scientist Ben Santer and Kerry Emanuel and historian and activist Naomi Oreskes.

“They are dangerous attempts to elevate the status of minority opinions, and to undercut the legitimacy, objectivity and transparency of existing climate science,” the three wrote in a recent Washington Post op-ed.

Defenders of the “consensus” argue the existing peer-review process works well and a red-blue team dynamic is not needed. They further argue scientific bodies, like the Intergovernmental Panel on Climate Change, provide a forum for scientific debates.

“Developing science, far from being ignored, is confronted directly and openly in such assessments,” Santer, Emanuel and Oreskes wrote.

This is very, very revealing. What Pruitt is planning threatens the role of people like Santer and Emanuel as gatekeepers–although “trolls under the bridge” is probably a better metaphor. They dominate peer review, through a variety of mechanisms. They are the editors of the journals. They are the go-to referees. Look back at some of the references to peer review in the Climategate emails if you doubt this. No Little Skeptical Billy Goat or Medium Size Skeptical Billy Goat is going to make it over their bridge of peer review. But the sight of Pruitt and Trump playing the role of The Big Billy Goat Gruff has them quaking in fear.*

As for “scientific bodies, like the Intergovernmental Panel on Climate Change” providing a “forum for scientific debates”–don’t make me laugh. There was more open debate at Soviet Party Congresses in the 1930s. Again–these people dominate these forums, and like any guild or clerisy, they cannot tolerate the rise of competing forums where contrary voices may be heard.

This is all very revealing. Truly confident scientists would welcome the opportunity to prove in a very public way that they are right. They would welcome the opportunity to vanquish publicly–and if they are so right, to humiliate–their adversaries.

This lot is very fond of pointing out what transpired during the Scopes Monkey Trial. Well, here’s their opportunity to make their supposedly anti-science opposition a public laughingstock, just like Clarence Darrow did (unfairly, truth be told) in 1925. Yet they recoil at the prospect.

Telling, no?

Also telling is the refusal of many states to provide public records relating to voter registration and voting to the Trump administration’s Presidential Advisory Commission on Election Integrity. The media and the governing establishment heap scorn on anyone who dares suggest that there might be voting irregularities in the US. Well then–turn over the records so that it can be proved! If US elections in every jurisdiction in the United States are as pure as the driven snow (I snort writing that, being a Chicago native), you’d think these states would be falling over themselves to prove what a great job they are doing in achieving such an outcome, right?

They say that sunlight is the best disinfectant. Those–like the Climate Change Mafia and state election officials and pols–who shriek at the suggestion that sunlight be cast on their activities just might be germs.

* Looking back on my old Climategate posts, I stumbled across something I’d forgotten: that the Climate Mafia was truly ahead of its time in blaming its discomfiture on Russian hackers.  Just like Hillary and her minions and the media (but I repeat myself), they attempted to distract attention from the damning substance by attacking how the embarrassing emails came to light. I had a very Trumpian response, years before Trump was a political phenomenon–I praised the FSB. Hilarious.

 

Donald Trump, LNG Impressario: Demolishing the Putin Puppet Narrative

Filed under: Commodities,Economics,Energy,Politics,Russia — The Professor @ 9:50 am

If Trump has a signature policy issue, it is promoting US energy to achieve what he calls “energy dominance.” The leading edge of this initiative is the promotion of LNG. Immediately prior to his appearance at the G20 Summit (where ironically he will be tediously hectored on trade by the increasing insufferable Angela Merkel), he will speak Thursday at the “Three Seas Summit” in Poland, where he will tout American LNG exports as both an economic and security fillip to Europe, and in particular eastern Europe.

“I think the United States can show itself as a benevolent country by exporting energy and by helping countries that don’t have adequate supplies become more self-sufficient and less dependent and less threatened,” he said.

This strikes at the foundation of Putin’s economic and geopolitical strategy. Export revenues from gas and oil keep his country afloat and his cronies flush. He uses gas in particular as a knout to bludgeon recalcitrant eastern Europeans (Ukraine in particular) and as a lever to exercise influence in western Europe, Germany in particular.

Gazprom routinely sniffs that LNG is more costly than Russian gas, and that LNG will not appreciable erode its market share. That’s true, but illustrates perfectly the limitations of market share as a measure of economic impact. The increased availability of LNG, particularly from the US, increases substantially the elasticity of supply into Europe. This, in turn, substantially increases the elasticity of demand. As the low cost producer (pipeline gas being cheaper), Russia/Gazprom will continue to be the source of the bulk of the methane molecules burned in Europe, but this increased elasticity of demand will reduce Gazprom’s pricing power and hence its revenues.

Furthermore, the effect on short-run elasticities will be particularly acute. Pre-LNG, there were few sources of additional supply available in a period of days or weeks that could substitute for Russian gas cutoff during some geopolitical power play. With LNG, the threat of shutting off the gas has lost much of its sting: especially as LNG evolves towards a traded market, supplies can swing quickly to offset any regional supply disruption, including one engineered by Putin for political purposes. So LNG arguably reduces Putin’s political leverage even more than it reduces his economic leverage. This is particularly true given complementary European policy changes that permit the flow of gas to regions not serviced by LNG directly.

Trump is getting some pushback from domestic interests in the US (notably the chemical industry) because greater exports would support prices and deprive these industries of the cheap fuel and feedstock that has powered their growth (something totally unpredictable a decade ago, when the demise of the US petrochemical industry was a real possibility). But (a) Trump seems totally committed to his pro-export course, and (b) complementary efforts to reduce restrictions on supply will mitigate the price impact. So I expect the opposition of the likes of the Industrial Energy Consumers of America to be little more than a speed bump in his race to promoting energy exports.

This all reveals Trump for the mercantilist he is: imports bad, exports good. This is economically illiterate and incoherent, but it’s Trump trade policy in a nutshell. Economic coherence aside, however, Donald Trump, LNG Impressario totally demolishes the Putin puppet narrative. Not that you’d notice–the hysteria continues unabated, because reality doesn’t matter to the soi disant reality-based community.

Here we have Trump devoting the bulk of his non-Twitter-directed energies (and he is high energy!) to promoting an economic policy that hits Putin at his most vulnerable spot, economically and geopolitically. Whatever his Russia-related rhetoric, pace Orwell, he is objectively anti-Putin.

Not that this causes neo-McCarthyites even to experience cognitive dissonance, let alone to engage in a serious re-evaluation. To them, Trump is literally a Kremlin operative in Putin’s thrall. And nothing–not even Trump venturing to the heart of the area Putin and his ilk believe to be in Russia’s sphere of influence and loudly (very loudly) proclaiming that he is offering American gas to free Europe from its energy thralldom–will divert them from their non-stop narrative.

As an aside, I do Joseph McCarthy a grave disservice by comparing today’s mainstream media, the Democratic Party, Neocons, and large swathes of the Republican establishment to him. There was actually a far more substantial factual basis for his paranoia than there is for that of the anti-Trump brigades.

There is an irony here, though. I have often sneered at Putin (and when he was president, Medvedev), for acting like a glorified Secretary of Commerce, going around being the pitchman for Russian economic interests, in energy in particular. Stylistically, Trump is doing somewhat the same. But substantively, in Making American Energy (LNG particularly) Great, Trump is giving Putin a good swift kick in the stones.

Not that the promoters of the New Red Scare are paying the slightest heed. Which demonstrates that theirs is a completely partisan and grotesquely intellectually dishonest campaign.

July 1, 2017

All Flaws Great and Small, Frankendodd Edition

On Wednesday I had the privilege to deliver the keynote at the FOW Trading Chicago event. My theme was the fundamental flaws in Frankendodd–you’re shocked, I’m sure.

What I attempted to do was to categorize the errors. I identified four basic types.

Unintended consequences contrary to the objectives of DFA. This could also be called “counter-intended consequences”–not just unintended, but the precise opposite of the stated intent. The biggest example is, well, related to bigness. If you wanted to summarize a primary objective of DFA, it would be “to reduce the too big to fail problem.” Well, the very nature of DFA means that in some ways it exacerbates TBTF. Most notably, the resulting regulatory burdens actually favor scale, because they impose largely fixed costs. I didn’t mention this in my talk, but a related effect is that increasing regulation leads to greater influence activities by the regulated, and for a variety of reasons this tends to favor the big over the medium and small.

Perhaps the most telling example of the perverse effects of DFA is that it has dramatically increased concentration among FCMs. This exacerbates a variety of sources of systemic risk, including concentration risk at CCPs; difficulties in managing defaulted positions and porting the positions of the customers of troubled FCMs; and greater interconnections across CCPs. Concentration also fundamentally undermines the ability of CCPs to mutualize default risk. It can also create wrong-way risks as the big FCMs are in some cases also sources of liquidity support to CCPs.

I could go on.

Creation of new risks due to misdiagnoses of old risks. The most telling example here is the clearing and collateral mandates, which were predicated on the view that too much credit was extended via OTC derivatives transactions. Collateral and netting were expected to reduce this credit risk.

This is a category error. For one thing, it embodies a fallacy of composition: reducing credit in one piece of an interconnected financial system that possesses numerous ways to create credit exposures does not necessarily reduce credit risk in the system as a whole. For another, even to the extent that reducing credit extended via derivatives transactions reduces overall credit exposures in the financial system, it does so by creating another risk–liquidity risk. This risk is in my view more pernicious for many reasons. One reason is that it is inherently wrong-way in nature: the mandates increase demands for liquidity precisely during those periods in which liquidity supply typically contracts. Another is that it increases the tightness of coupling in the financial system. Tight coupling increases the risk of catastrophic failure, and makes the system more vulnerable to a variety of different disruptions (e.g., operational risks such as the temporary failure of a part of the payments system).

As the Clearing Cassandra I warned about this early and often, to little avail–and indeed, often to derision and scorn. Belatedly regulators are coming to an understanding of the importance of this issue. Fed governor Jerome Powell recently emphasized this issue in a speech, and recommended CCPs engage in liquidity stress testing. In a scathing report, the CFTC Inspector General criticized the agency’s cost-benefit analysis of its margin rules for non-cleared swaps, based largely on its failure to consider liquidity effects. (The IG report generously cited my work several times.

But these are at best palliatives. The fundamental problem is inherent in the super-sizing of clearing and margining, and that problem is here to stay.

Imposition of “solutions” to non-existent problems. The best examples of this are the SEF mandate and position limits. The mode of execution of OTC swaps was not a source of systemic risk, and was not problematic even for reasons unrelated to systemic risk. Mandating a change to the freely-chosen modes of transaction execution has imposed compliance costs, and has also resulted in a fragmented swaps market: those who can escape the mandate (e.g., European banks trading € swaps) have done so, leading to bifurcation of the market for € swaps, which (a) reduces competition (another counter-intended consequence), and (b) reduces liquidity (also counter-intended).

The non-existence of a problem that position limits could solve is best illustrated by the pathetically flimsy justification for the rule set out in the CFTC’s proposal: the main example the CFTC mentioned is the Hunt silver episode. As I said during my talk, this is ancient history: when do we get to the Trojan War? If anything, the Hunts are the exception that proves the rule. The CFTC also pointed to Amaranth, but (a) failed to show that Amaranth’s activities caused “unreasonable and unwarranted price fluctuations,” and (b) did not demonstrate that (unlike the Hunt case) that Amaranth’s financial distress posed any threat to the broader market or any systemic risk.

It is sickly amusing that the CFTC touts that based on historical data, the proposed limits would constrain few, if any market participants. In other words, an entire industry must bear the burden of complying with a rule that the CFTC itself says would seldom be binding. Makes total sense, and surely passes a rigorous cost-benefit test! Constraining positions is unlikely to affect materially the likelihood of “unreasonable and unwarranted price fluctuations”. Regardless, positions are not likely to be constrained. Meaning that the probability that the regulation reduces such price fluctuations is close to zero, if not exactly equal to zero. Yet there would be an onerous, and ongoing cost to compliance. Not to mention that when the regulation would in fact bind, it would potentially constrain efficient risk transfer.

The “comma and footnote” problem. Such a long and dense piece of legislation, and the long and detailed regulations that it has spawned, inevitably contain problems that can lead to protracted disputes, and/or unpleasant surprises. The comma I refer to is in the position limit language of the DFA itself: as noted in the court decision that stymied the original CFTC position limit rule, the placement of the comma affects whether the language in the statute requires the CFTC to impose limits, or merely gives it the discretionary authority to do so in the even that it makes an explicit finding that the limits are required to reduce unwarranted and unreasonable price fluctuations. The footnotes I am thinking of were in the SEF rule: footnote 88 dramatically increased the scope of the rule, while footnote 513 circumscribed it.

And new issues of this sort crop up regularly, almost 7 years after the passage of Dodd-Frank. Recently Risk highlighted the fact that in its proposal for capital requirements on swap dealers, the CFTC (inadvertently?) potentially made it far more costly for companies like BP and Shell to become swap dealers. Specifically, whereas the Fed defines a financial company as one in which more than 85 percent of its activities are financial in nature, the CFTC proposes that a company can take advantage of more favorable capital requirements if its financial activities are less than 15 percent of its overall activities. Meaning, for example, a company with 80 percent financial activity would not count as a financial company under Fed rules, but would under the proposed CFTC rule. This basically makes it impossible for predominately commodity companies like BP and Shell to take advantage of preferential capital treatment specifically included for them and their ilk in DFA. To the extent that these firms decide to incur costs (higher capital costs, or the cost of reorganizing their businesses to escape the rule’s bite) and become swap dealers nonetheless, that cost will not generate any benefit. To the extent that they decide that it is not worth the cost, the swaps market will be more concentrated and less competitive (more counter-intended effects).

The position limits proposed regs provide a further example of this devil-in-the-details problem. The idea of a hedging carveout is eminently sensible, but the specifics of the CFTC’s hedging exemptions were unduly restrictive.

I could probably add more categories to the list. Different taxonomies are possible. But I think the foregoing is a useful way of thinking about the fundamental flaws in Frankendodd.

I’ll close with something that could make you feel better–or worse! For all the flaws in Frankendodd, MiFID II and EMIR make it look like a model of legislative and regulatory wisdom. The Europeans have managed to make errors in all of these categories–only more of them, and more egregious ones. For instance, as bad as the the US position limit proposal is, it pales in comparison to the position limit regulations that the Europeans are poised to inflict on their firms and their markets.

 

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