By James Hamilton, J.D., LL.M., Principal Analyst, CCH Federal Securities Law Reporter; and CCH Derivatives Regulation Law Reporter.
While praising the overall financial reforms achieved by the Dodd-Frank Wall Street Reform and Consumer Protection Act, the IMF lamented the Act’s failure to consolidate US financial regulation. Although the Act did eliminate the Office of Thrift Supervision, it left intact the OCC, FDIC, and the Fed with significant and overlapping oversight responsibilities. In a first report on the Dodd-Frank legislation, the IMF also noted that, since the SEC and CFTC have similar and converging market oversight and conduct-of-business missions, a merger of the two agencies would have properly addressed the seeming artificiality of the present separation between securities and futures oversight, as well as end the complexities of reporting to two separate Congressional oversight committees which, in the IMF’s view, has led to inefficiencies and jurisdictional disputes.
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