Editor's Note: This is a monthly publication on economic trends and financial policy issues. In this publication you can read "The Longbrake Letter", an analysis of economic trends and conditions written by Bill Longbrake, as well as commentary on financial regulation and policy written by members of the law firm Barnett, Sivon & Natter, P.C., a Washington, DC based law firm that specializes in financial services law.

ISSUE: #55, December 2014

The Longbrake Letter
- Bill Longbrake
In this month's letter, Bill Longbrake provides a brief overview of key global economic themes as we end 2014 and enter 2015. There is also an in-depth assessment of the impacts and potential consequences of the recent 45 percent crash in oil prices. He also provides a year-end assessment of observations he made a year ago about how the U.S. and global economies might fare in 2014 – noting what he got right and the many things he didn't. He then speculates about what might happen in 2015 and outlines key risks to the 2015 outlook.

CFPB and Potential Breaches of its Data Security Systems
- Bob Barnett
Cyber security risks are now sufficiently great and the damages from intrusions sufficiently large, that private sector entities delivering data under mandate to federal agencies should do so under agreements that the agency will not disclose information other than as agreed upon. In addition, if breaches in the data security systems of the agency creates damages for the reporting entity, the agency will hold it harmless.

The Swaps Amendment in the Omnibus Appropriations Bill
- Ray Natter
There is much misinformation currently in the press concerning the amendment to the "Swaps Push Out" that was originally passed as part of the 2010 Dodd-Frank Act. A review of the legislative history of the amendment indicates that it was a bi-partisan provision, includes language proposed by Minority Members of the House Financial Services Committee, and passed with strong support from Members on both sides of the aisle.

Designating Systemic Institutions: Is the Federal Reserve Board's Proposal for Designating GSIBs a Model for FSOC Designations?
- Jim Sivon
This article describes the quantitative methodology the Board has proposed for determining whether a bank holding company is systemically important, and suggest that FSOC consider a similar, quantitative approach to its systemic determinations.

     
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