Todd Phillips

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Todd Phillips

Todd Phillips

@tphillips

Banking and administrative law. Klaros. Fmr @RobinsonCollege @amprog @fdic @acusgov.

Washington, DC Katılım Mart 2008
729 Takip Edilen3.3K Takipçiler
Todd Phillips
Todd Phillips@tphillips·
This week I start a new role at Klaros! It's bittersweet to be leaving academia, but I'm excited about the prospect of using my knowledge to help banks, fintechs, and other financial institutions navigate regulatory challenges.
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Todd Phillips
Todd Phillips@tphillips·
The preamble by FFIEC to this proposal to rewrite the CAMELS ratings is unbelievably short. Nothing about the motivation or consequences to financial stability or society. Notice and comment isn't required for this, so that they're even putting it out is a good thing, but still.
Bank Reg Blog@bank_reg

Proposed CAMELS changes out today show how the hodgepodge of FFIEC regulators are trying to square this circle. Management rating would stick around but... (1) would no longer receive outsize weight in determining composite rating and (2) would focus on material financial risk

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Todd Phillips
Todd Phillips@tphillips·
Join me in DC on June 5 for the @theOpenBanker Salon! It's at the Aspen Institute, and will include a room full of smart people who care about financial policy. If you're not yet registered, use the discount code SPEAKER15 for 15% off.
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Cory
Cory@corychansen·
@tphillips You had never seen it??
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Todd Phillips
Todd Phillips@tphillips·
After having watched The Devil Wears Prada for the first time, my take away is this: It's well done, passes the Bechdel Test, and unrealistic because Andy would never get a good recommendation as a body-person who left her boss as they were going into a big media event.
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Todd Phillips
Todd Phillips@tphillips·
@vtg2 Has the Fed ever explained why they don't have the VC serve as acting chair (other than politics)?
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Victoria Guida
Victoria Guida@vtg2·
NEW: Fed Chair Jerome Powell, whose term atop the central bank ends Friday, will stay on in an acting capacity until Kevin Warsh is officially sworn in. It might take some time for Warsh to be officially sworn in to the job for procedural reasons federalreserve.gov/newsevents/pre…
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Todd Phillips
Todd Phillips@tphillips·
@Farrell1969 The CFTC entered into a consent agreement with Polymarket during the Biden administration, and my understanding is that the CFTC was in the midst of investigating breaches of that agreement when the election happened. The Trump CFTC dropped the investigation.
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James Farrell
James Farrell@Farrell1969·
@tphillips It would be hard to go after conduct on a "foreign" exchange without also charging unregistered activity by that exchange (if the bad conduct is enough to get US jdxn over bad guy using platform, then should also serve as jdxn for unregistered activity by platform itself).
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Brendan Pedersen
Brendan Pedersen@BrendanPedersen·
Lummis #126: providing investor protection enforcement at the SEC / CFTC Warrens calls the amendment "fig leaf #9" Bipartisan support, 18-6, adopted
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Brendan Pedersen
Brendan Pedersen@BrendanPedersen·
Good morning from the Senate Banking Committee. We’re minutes away from a markup of a landmark crypto bill, the Clarity Act. Reporters are hunting for power outlets and audience members are whispering about Polymarket odds. Follow along.
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Todd Phillips
Todd Phillips@tphillips·
I was on @MPRnews talking about--what else--prediction markets. Minnesota's legislature passed an anti-PM bill that the governor is likely to soon sign. What will happen then? Lawsuits.
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Rob Schwartz
Rob Schwartz@FormerCFTCGC·
@tphillips @fairplaygov @MickBransfield The CFTC’s market surveillance function is separate, and the exchanges are required to keep extensive records that the Commission (or DoJ for that matter) is entitled to inspect.
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Todd Phillips
Todd Phillips@tphillips·
In which the CFTC says that fully-collateralized event contract transactions don't need to be reported to swap data repositories. Seems bad.
CFTC@CFTC

.@CFTC Staff Issues No-Action Letter on Data Reporting for Event Contracts: cftc.gov/PressRoom/Pres…

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Todd Phillips
Todd Phillips@tphillips·
@FormerCFTCGC @fairplaygov @MickBransfield My thinking is that you don't need this info for systemic risk purposes, but the CFTC would probably want it to search for insider trading, rather than solely relying on exchanges to police that. But idk enough about how the CFTC uses this info.
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Rob Schwartz
Rob Schwartz@FormerCFTCGC·
The only thing I wonder about is whether there is a scenario where something like a cyber attack could make the CFTC wish it had SDR information on these swaps, but I haven’t fully processed that thought. Certainly nobody’s going to lock you in a mental institution for thinking the same reporting and record keeping requirements aren’t necessary as they are for riskier margined transactions. /end
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Todd Phillips
Todd Phillips@tphillips·
@TimHite Risk and leverage-based capital requirements, for sure. Stablecoin issuers are fractional reserve banks, just with a smaller maturity mismatch. T-bills are loans.
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Tim Hite
Tim Hite@TimHite·
@tphillips Which rules, specifically? If most banking rules were developed to address the risks associated with a fractional reserve banking system, that would be odd to apply the same here?
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Todd Phillips
Todd Phillips@tphillips·
Apropos of the CLARITY Act markup later this week, I'm really surprised that people haven't been making more of the effects of the portfolio margining provisions on SIPC. Either expand SIPC insurance to derivatives and commodities, or keep accounts separate.
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