A way through the fog of CFTC Title VII final rules, exemptive orders and no action letters is offered by Commissioner O'Malia's speech to Energy Risk 2013.  He uses a Rumsfeld-like categorization of known unknowns and unknown unknowns to sum up what's still to be done and to be discovered as a result on reporting, clearing and SEFs and cross-border application. I noticed in particular that he's picked up on Harvard Professor Roe's draft paper proposing that OTC clearing is no silver bullet for systemic risk – which Ben Larah posted about recently – here. Jon S.