In this report, we identify the policy consequences of BNY-Mellon’s newly-announced, severe payment-clearing problem.  Following as it does the bank’s 2015 operational problems handling fund settlements and growing regulatory concern about clearing-concentrations, we think the issue will reignite discussion of how to regulate financial-market utilities (FMUs).  From a political perspective, this aspect of the post-crisis framework has received only passing attention, but it is critical to financial-market stability and thus one to which strategic consideration and advocacy may well need to turn.  Much discussion has focused on CCPs, but FMU issues transcend these new entities to cover an array of payment, settlement, and clearing services conducted in GSIBs and/or large independent entities.

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