#disclosure

16 01, 2024

DAILY011624

2024-01-16T16:33:43-05:00January 16th, 2024|2- Daily Briefing|

Waller Raises Stakes for End-Game Finalization

Going beyond his longstanding critique of the end-game rules, FRB Gov. Waller today reflected industry comments and litigation plans, saying that he now thinks the proposal needs a “major overhaul” or should be withdrawn and reissued.  As we noted in our recent 2024 outlook, Gov. Bowman will surely side with this view, but Chair Powell holds the gavel when it comes to the end-game outcome at the Federal Reserve.  Mr. Waller also is personally opposed to the pending rewrite of debit-card interchange fees (see FSM Report INTERCHANGE12) because it forces the Fed to pick winners and losers.

Global Regulators Try Transparency as Cure to CCP-Margin Risk

The Basel Committee, CPMI, and IOSCO today released a long-planned consultation on CCP and clearing-member margining practices.  These are designed to limit the volatile and potentially-systemic liquidity stresses due to margining practices evident in 2020 and again after the Ukraine invasion, with the extent to which these further shift cost burdens from CCPs to clearing members their most controversial aspect.  Largely focused on transparency, the new approach would require CCPs to provide clearing members with margin-simulation tools that members would then make available to end-users to enhance margin-call preparedness.

Daily011624.pdf

25 10, 2021

M102521

2023-06-05T14:00:47-04:00October 25th, 2021|6- Client Memo|

The Three Top Priorities for CFPB’s Bigtech Rewrite

In early 2019, FedFin issued a report highlighting an array of hazards as bigtech’s “surveillance capitalism” business model increasingly subsumed financial services.  On Thursday, the Consumer Financial Protection Bureau finally took the first step  – a giant step – towards the wholesale rewrite of the U.S. bigtech industry that’s only become still more urgent.  Finance is structurally, systemically, and equitably different when someone who tracks what kind of underwear we like also knows how much money we have, where we spend it, and who holds it.  Given this, the Bureau’s full-bore attack on bigtech may well realign the sector’s competitive construct not just in the U.S., but also around the world.  This can be for the way-better if the Bureau picks its targets well and stands its ground under the ruthless barrage sure to start at hearings later this week.

M102521.pdf

25 10, 2021

Karen Petrou: The Three Top Priorities for CFPB’s Bigtech Rewrite

2023-06-05T14:00:57-04:00October 25th, 2021|The Vault|

In early 2019, FedFin issued a report highlighting an array of hazards as bigtech’s “surveillance capitalism” business model increasingly subsumed financial services.  On Thursday, the Consumer Financial Protection Bureau finally took the first step  – a giant step – towards the wholesale rewrite of the U.S. bigtech industry that’s only become still more urgent.  Finance is structurally, systemically, and equitably different when someone who tracks what kind of underwear we like also knows how much money we have, where we spend it, and who holds it.  Given this, the Bureau’s full-bore attack on bigtech may well realign the sector’s competitive construct not just in the U.S., but also around the world.  This can be for the way-better if the Bureau picks its targets well and stands its ground under the ruthless barrage sure to start at hearings later this week.

That the CFPB contemplates an incoming fusillade is clear from its order.  All it demands of Amazon, Apple, Facebook, Google, PayPal, and Square makes daunting reading even if one doesn’t have to fill in seventeen pages of penetrating questions and provide all the supporting documentation demanded on each one of them.  Tech platforms are told to hand over memos, names, product numbers, contracts, operating manuals, and pretty much anything else anyone might think of for any aspect of recent bigtech operation that touches consumer finance.  The full scope of all these data demands is stunning, but perhaps the most interesting among them focus on data harvesting, surveillance-based advertising, targeted offers, …

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