{"id":1473,"date":"2011-07-21T00:31:43","date_gmt":"2011-07-21T04:31:43","guid":{"rendered":"http:\/\/journals.law.harvard.edu\/hblr\/?p=1473"},"modified":"2016-07-04T21:55:13","modified_gmt":"2016-07-05T01:55:13","slug":"lofchie-straight-talk","status":"publish","type":"post","link":"https:\/\/journals.law.harvard.edu\/hblr\/lofchie-straight-talk\/","title":{"rendered":"Straight Talk from a Practitioner: Notes from Under the Wall"},"content":{"rendered":"

Download PDF<\/a><\/p>\n

Steven Lofchie*<\/a> with assistance from Theresa Perkins**<\/a><\/p>\n

As a financial regulatory lawyer, I am accustomed to being cautious in my pronouncements.\u00a0 Equivocal and timid.\u00a0 When clients ask me for hard advice, rather than answer them, I often just rub my hands together like Uriah Heep and mumble, \u201cthat is a very good question.\u201d\u00a0 If you search me on the Internet, you will see that my writing resulted in one commenter describing me as \u201cthe world\u2019s most boring man.\u201d[1]<\/sup><\/sup><\/a><\/p>\n

Nonetheless, I can tell you with absolute certainty, flat opinion\u2014none of those scrivener \u201cit\u2019s the better view\u201d qualifications\u2014that Dodd-Frank just does not work.\u00a0 It\u2019s a horrorshow.\u00a0 In fact, sometimes I get so agitated in my opposition to the statute that, when I speak, my hands tremble as with palsy, my eyes redden with little flecks, and I let fly bits of spittle.[2]<\/sup><\/sup><\/a><\/p>\n

So it surprises me, frustrates me, infuriates me, that the statute has its many and public defenders.\u00a0 The newspapers still love it.[3]<\/a>\u00a0 So I bemoan and let fly.<\/p>\n

Two Debates?<\/strong><\/p>\n

There are, in fact, two debates going on about Dodd-Frank.\u00a0 Actually, \u201cdebates\u201d is the wrong word.\u00a0 Dodd-Frank proponents (the newspapers, the general public, even my wife I am sad to say) believe that when it comes to financial regulation, we need \u201cmore.\u201d\u00a0 Or, alternatively, that we should have \u201creform.\u201d<\/p>\n

But to a working lawyer, \u201cmore\u201d and \u201creform\u201d are empty phrases.\u00a0 Might as well tell me that financial regulation requires more mom and apple pie, allowing us to have more chickens with our more pots, cars and garages.<\/p>\n

At a slightly more sophisticated level, the public proponents might toss out a term like \u201ctransparency.\u201d\u00a0 Now \u201ctransparency\u201d sounds weightier than simply \u201cmore,\u201d or even than \u201creform.\u201d\u00a0 So step back and I will let fly a bit.<\/p>\n

The Government Needs More Information About Swaps<\/strong><\/p>\n

CFTC Chairman Gensler leads the public side of the debate about swaps.\u00a0 He has made the case for \u201ctransparency\u201d as follows:<\/p>\n

The [Dodd-Frank] Act includes robust recordkeeping and reporting requirements for all swaps transactions. It is important that all swaps \u2013 both on-exchange and off \u2013 be reported to data repositories so that regulators can have a window into the risks posed in the system and can police the markets for fraud, manipulation and other abuses.[4]<\/sup><\/sup><\/a><\/p>\n

At the level of complete and meaningless generality at which the public debate operates, I have no quarrel with Chairman Gensler.\u00a0 If it will be useful for the U.S. government to have more information about swaps so that it can do the job of financial regulation properly, I am happy for it.\u00a0 I don\u2019t have any philosophical objections, nor do I believe that there is some right of privacy with respect to financial instruments.\u00a0 Given that I am accustomed to working with closely-regulated financial entities, I assume that everything that I, or my clients, do or write is subject to the review of the government.<\/p>\n

In fact, my concession is more abject than Chairman Gensler\u2019s demands.\u00a0 Chairman Gensler only wants information about \u201cswaps.\u201d\u00a0 For myself, I am willing to concede that the government may require information as to every contract that is either (i) entered into in the United States or (ii) that is entered into outside the United States but could have an effect on the United States.<\/p>\n

Suppose that, instead of only asking for swaps information, Dodd-Frank had said \u201cany agency of the U.S. government may require any individual or entity doing business or having offices in the United States, or doing business outside the United States that may have an effect on the United States, to report such information on any contract into which it enters as any such U.S. agency may require, in such form and on such timing as the agency requires, in the public interest.\u201d\u00a0 It would be ok with me.\u00a0 I am not a libertarian.\u00a0 I understand that there may be certain specific types of contracts protected by the First Amendment (such as who buys particular books), but that is a detail.\u00a0 Very few financial contracts, and no swaps, are protected in this regard.<\/p>\n

Now, having said that I completely and utterly concede to Chairman Gensler in his desire to protect the economy, let me impose my few caveats (of reasonableness).\u00a0 (i) The cost of collection of the information by market participants and the transfer of that information to the government should be reasonable.\u00a0 (ii) The government should be able to make some reasonable use of that information, at a reasonable cost, and that cost should be reasonable in light of the other tasks of the government, given that the government does not have infinite resources.<\/p>\n

Under the CFTC\u2019s proposed rules, firms entering into swaps regulated by the CFTC must report somewhere around 30 or 40 data items about the swap within 15 minutes of the trade.[5]<\/sup><\/sup><\/a>\u00a0 Among these data items are whether (i) the swap is uncleared, which means that it will be subject to individually negotiated collateral terms, and (ii) whether the swap is \u201cbespoke,\u201d which the CFTC defines as a term, not reported, that is \u201cmaterial\u201d to the transaction.<\/p>\n

Now, if either of these two boxes is checked, all the rest of the 30 or 40 data items of information reported to the CFTC are essentially worthless.\u00a0 Even if the two boxes are not checked, the other 30 or 40 fields of information are just too much data to be cheap to deliver, and too little data to be useful.<\/p>\n

For example, let\u2019s say that the trade is a currency option on an Asian currency. The CFTC\u2019s data form provides for 8 fields of information about options, each of the 8 fields having multiple choices, including \u201cother,\u201d meaning again that all of the collected information will be useless.\u00a0 Now, it so happens that one of the major risks with trading in Asian currencies is that the currency may become inconvertible.\u00a0 In that case, the parties may seek to get out of the trade, or they may be stuck with a trade or with currencies that they do not want to hold, and they will have to make arrangements to deal with this contingency.\u00a0 Without knowing how the parties dealt with the non-convertibility issue on an Asian currency swap (which is not one of the CFTC data items), all of this other information is useless.<\/p>\n

Cost\/Benefit<\/strong><\/p>\n

It is that way for pretty much everything that the CFTC wants to collect on swaps: too much information to be done cheaply; too little information to be useful.<\/p>\n

Except that the CFTC says that this information collection effort is not expensive.\u00a0 In fact, the expense of collecting these 30 or 40 items of data (each of which has numerous possible choices and calculations) and reporting them to the regulators is so \u201cminimal,\u201d[6]<\/sup><\/sup><\/a> that the CFTC says it is not even worth the bother of trying to determine the cost.<\/p>\n

Really?\u00a0 That minimal?[7]<\/sup><\/sup><\/a><\/p>\n

I, on the other hand, am not persuaded that the CFTC is making a serious effort to determine what the costs of obtaining this information will be, what the costs of using this information will be, and how useful this information will be to market participants.[8]<\/sup><\/sup><\/a><\/p>\n

In the best of all Panglossian worlds where there was an infinite amount of money to be spent on financial regulation, both as to the costs of compliance by the regulated and as to the costs of regulation by the government, these questions of practicality and benefit would not matter.\u00a0 If the regulators adopt rules that don\u2019t work, it is just money down the drain; plenty more where that came from.<\/p>\n

In the harsh MMA-world in which we actually live, where we are running up against the debt ceiling, where we know at some point the taxes are likely to go up, and government support payments are likely to go down, the way in which we spend our regulatory dollars does matter.\u00a0 There is a limited tonnage of these dollars.\u00a0 Money wasted collecting useless information about swaps is money that could be spent on something that better protects the economy or investors.<\/p>\n

Moreover, wasteful regulation has other negatives.\u00a0 Building systems to comply with useless reporting regulations is expensive, driving small players out of the industry, reducing competition, worsening the problem of \u201ctoo big to fail.\u201d\u00a0 Regulatory costs are essentially a tax that must be paid by somebody, presumably at least in part by customers.\u00a0 In addition, bad or expensive regulations lose jobs, drives them overseas.\u00a0 Beyond that, bad and expensive regulations result in a reduction of respect for the government.\u00a0 It makes one feel that the government just can\u2019t act effectively, and I would very much like to believe that it can.<\/p>\n

How to Do It Better<\/strong><\/p>\n

While I do not believe that any good can or will come out of Dodd-Frank, there are ways to make it less of a waste.\u00a0 Start with smaller regulations and test their effectiveness.\u00a0 It would be more reasonable to start with collecting monthly aggregate swaps data, as that would give a sense of the parameters and scope of the task of collecting individual trade data and give some guidance as to what individual trade data would be useful.<\/p>\n

Or try a pilot program.\u00a0 Under Dodd-Frank, the CFTC has been collecting information on \u201cpre-existing\u201d pre-Dodd-Frank swaps for a considerable period.\u00a0 (I am curious if any benefit has come from this collection.)\u00a0 On the basis of this information, the CFTC could design a limited pilot program for reporting trade data on particular types of swaps: soybean swaps, hurricane swaps, an EU sovereign swap, a Ringgit swap.\u00a0 Then the results of the pilot program could be published.\u00a0 Maybe a sequence of transaction information could be released gradually through a week of trading days, just as the CFTC imagines its system will work.\u00a0 That would give market participants (buy- and sell-side) and economists a chance to analyze the information and see whether it is of any use and would also allow a better opportunity to analyze costs.<\/p>\n

If the tests in a pilot program show that all of this information the CFTC wants to collect about swaps is useful and cost-effective, I have no objection.\u00a0 We will have waited an additional few months for our data on soybean swaps, but I suspect that the economy can survive that.\u00a0 The risk to the financial regulatory system of building a useless information trash receptor seems greater to me than the risk of delay, test and evaluate.<\/p>\n

Lastly, understand I just picked the topic of trade reporting because it is fairly simple.\u00a0 The statute is 2,000 pages, and more than a problem per page.<\/p>\n

 <\/p>\n

\n
\n
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<\/a>* Steven Lofchie is a Partner at Cadwalader, Wickersham and Taft in New York. He is Co-Chairman of the Financial Services Department at Cadwalader, and is a senior fellow for legal studies at the Center for Financial Stability. See<\/em> Center for Financial Stability, http:\/\/www.centerforfinancialstability.org.<\/p>\n<\/div>\n

\n

<\/a>** Theresa Perkins is a summer associate at Cadwalader, Wickersham and Taft and a J.D. Candidate (2012) at Boston University School of Law.<\/p>\n<\/div>\n

\n

<\/a>[1] Steven Lofchie, We Salute You!<\/em>, Small Thoughts, Mar. 26, 2009, http:\/\/xerpentine. blogspot.com\/2009\/03\/steven-lofchie-we-salute-you.html.<\/p>\n<\/div>\n

\n

<\/a>[2] See also<\/em> Feodor Dostoevsky, Notes from the Underground 1 (\u201cI am a sick man….\u00a0 I am a spiteful man.\u00a0 I am an unattractive man.\u00a0 I believe my liver is diseased.\u201d).<\/p>\n<\/div>\n

\n

<\/a>[3] See, e.g.<\/em>, Edward Wyatt, Financial Reforms of Dodd-Frank Act Still Under Fire a Year Later<\/em>, N.Y. Times, July 19, 2011, at B1, B5.<\/p>\n<\/div>\n

\n

<\/a>[4] Gary Gensler, Chairman, U.S. Commodity Futures Trading Comm\u2019n, Remarks on the OTC Derivatives Reform to the Economic and Monetary Affairs Committee in Brussels, Belgium (Mar. 22, 2011).<\/p>\n<\/div>\n

\n

<\/a>[5] Highlighting the unrealistic nature of the 15 minute reporting requirement, when the Transaction Reporting and Compliance Engine system (\u201cTRACE\u201d) was introduced, reporting took 75 minutes, and \u201creporting requirements for swaps are significantly more complex.\u201d See<\/em> Kenneth E. Bentsen, Comment to the CFTC Regarding Real-Time Reporting and Swap Data Recordkeeping, International Swaps and Derivatives Association, Inc. 12 (Feb. 7, 2011).<\/p>\n<\/div>\n

\n

<\/a>[6] See<\/em> Reporting, Recordkeeping, and Daily Trading Records Requirements for Swap Dealers and Major Swap Participants, 75 Fed. Reg. 236, III(C) (proposed Dec. 9, 2010) (to be codified at 17 C.F.R. pt. 23).<\/p>\n<\/div>\n

\n

<\/a>[7] Problems arise with regards to both the amount of data collected and the recordkeeping form the data must be stored in. See<\/em> id<\/em>. at 32 (noting the difficulties in gathering data on pre-execution communications, up to the minute timestamps for quotations given or received before an execution, and swap portfolio reconciliations because \u201cindustry participants do not typically capture all this data\u201d); id.<\/em> at 31 (noting the significant costs associated with \u201caggregating transaction data from all systems into a single . . . file,\u201d maintaining records for five years after the life of a swap, and making real-time records instantly accessible given the large volume of transactions occurring each day).<\/p>\n<\/div>\n

\n

<\/a>[8] Failing to obtain, or making any serious effort to obtain, such a cost estimate seems contrary to President Obama\u2019s Executive Order 13,563. See<\/em> Exec. Order No. 13,563, 76 Fed. Reg. 3821 (Jan. 21, 2011) (requiring agencies to \u201cpropose or adopt a regulation only upon reasoned determination that its benefits justify its costs\u201d).<\/p>\n<\/div>\n<\/div>\n

 <\/p>\n

\n

Preferred citation: Steven Lofchie and Theresa Perkins,\u00a0Notes from Under the Wall<\/em>, 2 Harv. Bus. L. Rev. Online 10 (2011), https:\/\/journals.law.harvard.edu\/hblr\/\/?p=1473.<\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

Steven Lofchie and Theresa Perkins: As a financial regulatory lawyer, I am accustomed to being cautious in my pronouncements. Equivocal and timid. 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