Evaluating the sustainability of the global financial system.I focus on the undercapitalization and inflated credit ratings of uncleared swaps and securitizations.10 years after the global financial catastrophe, global policy makers are casting about for ways to jumpstart growth.My work shows that more under-capitalized swaps and securitzations are not the answer.

I resigned from my much-loved job at Debtwire ABS to prepare and submit a comprehensive proposal on the capitalization of uncleared/unmarginable swaps with RAC provisions and a flip clause to the CFTC and OMB.My concern was that Trump appointees at the CFTC and prudential regulators might go easy on this type of swap, which was a core component of the CDOs, CDS, RMBS, repackagings and other ABS that started and fueled the financial crisis.My submission "Re: RIN 3038 AD54 'Capital Requirements for Swap Dealers and Major Swap Participants'” of 4 May 2017 can be linked from either of the first two media further below. The first is a summary that I published on LinkedIn on 5 May 2017. The second links to my submission on cftc.gov.(The third media is the NYTimes Fair Game article on the work of my Wikirating.org colleagues and me by Gretchen Morgenson 'Should Free Markets Govern the Bond Rating Agencies' of 5 May 2017. The fourth and fifth media are two of my LinkedIn articles on flawed rating assumptions for derivative contracts.)"A Suggested Improvement to the CFTC Proposal."The Federal Register published the CFTC Proposal (Volume 81, Number 242, pages 91252-91334) on 16 December 2016. The acronyms used therein have the same respective meanings in this response.“'Section 731 of the Dodd-Frank Act amended the CEA by adding section 4s(e), which requires the Commission to adopt rules establishing capital requirements for SDs and MSPs to help ensure the safety and soundness of the SDs and MSPs.'""I urge the Commission to adjust the CFTC Proposal in the following way."An SD or MSP that is exposed to a flip clause, walkaway or similar provision in an uncleared swap or uncleared security-based swap must hold capital equal to the following for each such swap."The maximum of: [0, 100% of the “uncleared swap margin” as defined in footnote 25 of the CFTC Proposal + 100% of the market value of the swap or security-based swap on the books of the SD or MSP]."

Byline journalist for wire service that provides sector-leading intelligence to hedge funds, law firms and other subscribers. Analyzed derivative contracts, asset-backed securities (ABS), rating methodologies, international regulation of the preceding and bankruptcy rulings.NOTEWORTHY REPORTING• Definitive series on the impact of the US swap margin rule on ABS investors, issuers and ratings. See below.• Illustrated the rating agency practice of upgrading the derivative and other contracts of weak banks to avoid downgrading ABS when issuers are party to these contracts. See "Moody's bets..." in Summary.• Mapped circularity of inflated ratings of student loan ABS (SLABS), inflated ratings for the largest sponsor Navient Corp. and inflated valuations of its residual interests in long-term SLABS.• Measured crisis-era structures such as combination securities, flip clauses and JPY repackagings that underwriters of Collateralized Loan Obligation (CLO) continue to use.• Evaluated ABS sectors such as rent-to-own and Italian non-performing loans.RESPONSIBILITIES• Coupled primary research and journalistic follow-up to write and post original content. Articles ranged from 400 to 3,000 words. Several can be linked either below or from Summary. Others available on request.• Provided real time analysis of rating actions and regulatory developments to 15 editor and journalist colleagues in multiple US and EU locales.• Identified breaking announcements for immediate aggregation posting.• Chose articles for social media colleagues to release publicly on the Debtwire Exclusives site and promote. Wrote and edited promotional text.• Built relationships with outside press, financial regulators, legislative staffs, think tank researchers and consumer finance lobbyists.• Panelist at the Center for American Progress event "Exploring Shadow Banking – Can the Nation Avoid the Next Crisis?" in Washington DC on 12 July 2016 . See Summary section for link.

Fulltime, self-financed and highly-resourceful expansion of work that I did as a derivatives and ABS analyst at Moody’s Investors ServiceGOALS• Improve market information that individuals and firms use to make economic decisions• Decrease systemic risk and avoid bailouts• Improve the public understanding of the origins of the financial crisisACCOMPLISHMENTS• Apprised regulators of the under-capitalization of an uncleared, non-margined swap contract with RAC provisions and a flip clause—the go-to swap contract for ABS issuers worldwide• Provided rationales that US regulators cited in rules that subject this type of swap contract to best practice, i.e., the daily exchange of variation margin• Thanked by state AGs for analyses submitted over four years that supported the settlement dated 13 January 2017 between: the US DoJ, 21 state and the DC AGs; and Moody’s Corporation, Moody’s Investors Service and Moody’s Analytics• Briefed the Alt Banking group of Occupy Wall Street; the credit risk/ABS group of the NYFed; and US Rep. Nadler [D] 10th NY• Provided insights to US House investigation into MF Global and to UK Commons investigation into the role of rating agencies in the financial crisis• Asked by staff of US Rep. Neugebauer [R] 19th TX to review NRSRO section in US House report on MF GlobalPRODUCTION• 15 responses to comment requests by US and EU regulators (the CFTC, FDIC, Federal Reserve Board, FCA, FHFA, OCC, SEC, US Treasury, Bank of England, European Banking Authority, European Central Bank, European Commission, and ESMA• 10 on-the-record briefings with rule writing teams and staff• Analyses on derivatives and rating processes for five US and UK legislative inquiries and investigations• Five critiques of ABS derivative methodologies (4 to Moody’s and 1 to Fitch)• Research that formed the core of three Structured Credit Investor articles. Spoke at SCI investor conference on 29 Oct 2014 in New York

Go-to analyst for long-term engagements with challenging issuers and underwriters. Delivered best practice analyses of structured products that fused skeptical viewpoint with numeric, legal and qualitative detail. Wrote and presented plain language descriptions of complex deal proposals.RESPONSIBILITIES• Conveyed robust recommendations to rating committees and senior management.• Provided clear, exacting feedback to senior management, underwriters and issuers.• On-call resource for colleagues worldwide regarding derivative contracts in the corporate, municipal, sovereign, banking, structured and funds sectors.• Senior-most, outside member of 40 sovereign committees in 2009-2010.ACCOMPLISHMENTS• Spurred analyst colleagues, rating teams and committees to assign accurate rather than inflated ratings before, during and after the financial crisis.• Co-author and lead developer of best practice methodologies for providers of derivative contracts and ABS end users. See 'Publications' section, further below.• Continued best practice work to current date by resigning in July 2010 and directly engaging the industry and regulators on deficient practices that led to the financial crisis. See subsequent experience as Private Citizen Advocate, immediately above.

Specialist in non-USD fixed-income and currency products for New York trading floor.Representative transactions: • chooser FX option issued by a South American sovereign • levered spread on European swap indices paid in USD • levered note indexed to JPY/USD basis swap • option on government bond denominated in second currency.

Member of three-person team that forecast major currency pairs, cross rates and interest rates. Users included corporate subscribers and 30 colleagues that forecast macro and financial trends for the US, other G20 and emerging market economies.• Reinstated on-time distribution of The WEFA Group Monthly Foreign Exchange Rate Outlook, a significant contributor to the group’s earnings.• Co-authored the publication’s market overview, wrote articles on selected EC currencies.• Induced 15 colleagues to submit articles on time. Kept each production step on schedule.• Cultivated financial media to cover WEFA insights.

Conducted primary research as part of a 15-person management consulting team that assessed the nationwide markets for telecommunication and pharmaceutical products.• Representative project – interviewed staff of the 50 state utility commissions to help build state-by-state projections for a newly deregulated telecommunications product.