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Financial regulators overseeing the over-the-counter (OTC) derivatives market marked an important milestone this fall as Wall Street banks began complying with the last in a cocktail of derivatives market reforms intended to rein in systemic risk. This milestone signals the near completion of derivatives rules established in the wake of AIG’s bailout and Lehman Brothers’ failure.

Now that the global frenzy of crisis-era rule-making has ebbed, and the protective architecture is substantially complete, policy makers must increasingly turn their attention to a new chapter of reform: using data to right-size rules that cause unnecessary harm to smaller firms.

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