Today’s giant payment-service merger shows not only how quickly the payment system is evolving, but also the scale of core-infrastructure risks with which U.S. regulators must reckon. Standards for financial-market utilities (FMUs) have been largely overlooked as FSOC and financial regulators crafted and then deconstructed the Dodd-Frank rules for big banks and nonbank systemically-important financial institutions (SIFIs). Here, we analyze a major strategic question left unanswered in our assessment of FSOC’s proposed systemic-regulation guidelines: will U.S. regulators also rewrite the way FMUs now are designated and regulated?

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