Tuesday, January 25, 2022

The Fed Weighs in on a 'Digital Dollar'

Vast Cross-border Implications for Central Bank Digital Currencies

Author: David Schwartz J.D. CPA

A discussion paper published on January 20th invites the public to explore with the U.S. Federal Reserve Board the creation of a digital version of the U.S. dollar. A Central Bank Digital Currency (CBDC) backed by the Federal Reserve would be designed, according to the Fed’s paper, to compete with cryptocurrencies like Bitcoin and Ethereum. Comments are due by May 20, 2022.

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Saturday, January 22, 2022

Lenders and Borrowers Sound off on the SEC's Disclosure Proposal

Giving the SEC an Earful and Sounding the Alarm

Author: David Schwartz J.D. CPA

The Securities and Exchange Commission's (SEC) securities lending disclosure proposal has drawn sharp rebuke from both securities lenders and borrowers. Lending principals criticized the proposal on everything from cost, lack of clarity, and overbroad scope to the rule's general inequity. They also pointed out a host of potential unintended consequences that could work against the very transparency the rule proposal was intended to foster. 

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Tuesday, January 18, 2022

Balancing the Risks of Loan Disclosures for Traders

Is 10c-1 Regulatory Overreach? Or a Good Starting Point?

Author: Ed Blount

“The best trader I ever knew was broken when he took over a dying friend’s book. Everyone knew the book and turned on him.” Born in 1899, Henry Goldberg was the oldest trader on the floor of the New York Stock Exchange when I interviewed him in 1985. He answered my questions about trading expertise during a NYSE-sanctioned survey to find possible use cases for artificial intelligence. 

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Wednesday, January 5, 2022

FIRST DO NO HARM

A Hippocratic Oath for Securities Lenders

Author: Ed Blount

If the Securities and Exchange Commission approves the many industry requests for delay of its proposed 10c-1 reporting rule for securities loans, leaders in the Global Association of Securities Lending Associations (GASLA) should move quickly to create a more efficient and lower cost disclosure regime.

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Wednesday, December 15, 2021

Beneficial Owners: "Most at risk, yet least served" by Disclosures

Comments to SEC on Proposed 10c-1 Reporting by Securities Lenders

Author: Ed Blount

CSFME comments on proposed Rule 10c-1, as submitted 15 December 2021 to the Securities and Exchange Commission:

"With regard to the above-cited 10c-1 disclosure system, my colleagues and I consider inclusion in the rule proposal of an optional section on alternatives to be a genuine invitation to propose reasonable changes. We assume that the Commission must already realize that the mandated disclosure system, as currently proposed, will likely not achieve its goals.

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