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<div class="timestamp">November 3, 2012</div>
<h1>One Safety Net That Needs to Shrink</h1>
<h6 class="byline">By
<span>
<a href="http://topics.nytimes.com/top/reference/timestopics/people/m/gretchen_morgenson/index.html" rel="author" title="More Articles by GRETCHEN MORGENSON"><span>GRETCHEN MORGENSON</span></a></span></h6>
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<p>
ELECTION Day is upon us, and neither President Obama nor Mitt Romney has
really addressed one of the nation’s most pressing economic issues: the
risk that one day taxpayers might have to bail out swashbuckling
financial institutions again. </p>
<p>
Granted, the economic pain many are feeling now — the snail’s pace
recovery, the stubbornly high unemployment — is foremost in voters’
minds. But given all we’ve gone through after the last binge in the
financial industry, failing to confront the too-big-to-fail question is a
serious oversight. </p>
<p>
Many Americans probably think the Dodd-Frank financial reform law will
protect taxpayers from future bailouts. Wrong. In fact, Dodd-Frank
actually widened the federal safety net for big institutions. Under that
law, eight more giants were granted the right to tap the Federal
Reserve for funding when the next crisis hits. At the same time, those
eight may avoid Dodd-Frank measures that govern how we’re supposed to
wind down institutions that get into trouble. </p>
<p>
In other words, these lucky eight got the best of both worlds: access to the Fed’s money and no penalty for failure. </p>
<p>
Which institutions hit this jackpot? Clearinghouses. These are large,
powerful institutions that clear or settle options, bond and <a href="http://topics.nytimes.com/top/reference/timestopics/subjects/d/derivatives/index.html?inline=nyt-classifier" title="More articles about derivatives." class="meta-classifier">derivatives</a> trades. They include the <a href="http://topics.nytimes.com/top/reference/timestopics/organizations/c/chicago_mercantile_exchange/index.html?inline=nyt-org" title="More articles about Chicago Mercantile Exchange" class="meta-org">Chicago Mercantile Exchange</a>, the Intercontinental Exchange and the Options Clearing Corporation. All were designated as <a title="Details on the designation. " href="http://1.usa.gov/TYC0Xw">systemically important financial market utilities</a>
under Title VIII of Dodd-Frank. People often refer to these
institutions as utilities, but that’s not quite right. Many of these
enterprises run lucrative businesses, have shareholders and reward their
executives handsomely. Last year, the <a href="http://topics.nytimes.com/top/news/business/companies/chicago_mercantile_exchange_holdings/index.html?inline=nyt-org" title="More information about CME Group Inc" class="meta-org">CME Group</a>,
the parent company of the Chicago Mercantile Exchange, generated almost
$3.3 billion in revenue. Its chief executive, Craig S. Donohue,
received $3.9 million in compensation and held an additional $10 million
worth of equity awards outstanding, according to the company’s proxy
statement. </p>
<p>
Make no mistake: these institutions are stretching the federal safety
net. The Chicago Merc clears derivatives contracts with a notional value
in the trillions of dollars. I.C.E. clears most of the <a href="http://topics.nytimes.com/top/reference/timestopics/subjects/c/credit_default_swaps/index.html?inline=nyt-classifier" title="More articles about credit default swaps." class="meta-classifier">credit default swaps</a>
in the United States — billions of dollars a day, on paper. No wonder
they are considered major players in our financial system. </p>
<p>
But placing them at the bailout trough is wrong, according to Sheila
Bair, the former head of the Federal Deposit Insurance Corporation. In a
recently published book, Ms. Bair wrote that top officials at the
Treasury and the Fed, over the objections of the F.D.I.C., pushed to
gain access for the clearinghouses to Fed lending. </p>
<p>
The clearinghouses “were drooling at the prospect of having access to
loans from the Fed,” she wrote. “I thought it was a terrible precedent
and still do. It was the first time in the history of the Fed that any
entity besides an insured bank could borrow from the discount window.” .
</p>
<p>
“The Treasury’s and the Fed’s reasoning was that since another part of
Dodd-Frank was trying to encourage more activity to move to
clearinghouses, we should provide some liquidity support to them,” she
said in an interview last week. “Our argument back was, if you have an
event beyond their control with systemwide consequences, then you have
the ability to lend on a generally available basis. What they wanted was
the ability to lend to individual clearinghouses.” </p>
<p>
The clearinghouses have considerable clout in Washington. From the beginning of 2010 through this year, the CME Group has spent <a title="Information on CME lobbying." href="http://bit.ly/QZFkTR">$6 million lobbying</a>, according to the Center for Responsive Politics. </p>
<p>
Did these players push for special treatment while avoiding other
aspects of Dodd-Frank? Representatives of the Chicago Mercantile
Exchange and the Options Clearing Corporation say no, noting that access
to the Fed meant they would also be overseen by the central bank, in
addition to the Securities and Exchange Commission or the Commodities
Futures Trading Commission. </p>
<p>
But the Fed’s involvement is not likely to be intrusive, because
Dodd-Frank directed it to take a back seat to a financial utility’s
primary regulator, either the S.E.C. or the C.F.T.C. </p>
<p>
The CME said that it did not support Dodd-Frank’s designation of
clearinghouses as systemically important, but once it received the
designation, it believed the Fed should provide access to emergency
lending. The O.C.C. echoed this point. </p>
<p>
Whatever the case, the CME Group has argued that it should be exempt
from the orderly liquidation authority set up under Dodd-Frank. This
authority was designed to unwind complex and interconnected financial
firms that could threaten the financial system if they failed. The law
appointed the F.D.I.C. as receiver to resolve teetering entities. That
authority is supposed to end the problem of institutions that are too
big to be allowed to fail and also to hold their managers accountable.
</p>
<p>
BUT in a<a title="Link to the letters." href="http://1.usa.gov/TYCUTY"> letter to the F.D.I.C.</a>
a few months after Dodd-Frank became law, the CME Group asked the
F.D.I.C. to confirm that the exchange wouldn’t fall under that
authority’s jurisdiction. It is not a financial company as defined by
the law, the CME contended, and therefore should not be subject to the
resolution process. </p>
<p>
The F.D.I.C. has not confirmed the C.M.E.’s view on the matter. But it seems to be gaining traction among other regulators. At <a title="LInk to the presentation. " href="http://bit.ly/TYDfGa">an Aug. 2012 presentation last August</a>
on resolving financial market utilities, Robert S. Steigerwald of the
Federal Reserve Bank of Chicago noted that it was unclear whether a
financial utility such as the Chicago Merc would have to be wound down
as required under Dodd-Frank. </p>
<p>
So these large and systemically important financial utilities that
together trade and clear trillions of dollars in transactions appear to
have won the daily double — access to federal money, without the
accountability. </p>
<p>
“Dodd-Frank should have been all about contracting the safety net,” Ms.
Bair said last week. “But this was a huge and unprecedented expansion
of the safety net that provided expressed government support for
for-profit entities. These financial market utilities are the new
government-sponsored enterprises.” </p>
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