The timing of these articles is very important for the repo market. Earlier this year, DTC asked the SEC for a rule change on "legal" language in its rule book that it uses in its communications with members. This rule change while discussing GCF repo in some detail, failed to state to the SEC anything about the significant change in the interbank clearing of GCF repo which will affect the repo market in less than three months. While the chart shows that interbank GCF repo is just 10 to 15% of total volume for GCF traded, this is a major change in the concept in how GCF repo evolved for a still very vulnerable market. This research piece while first in the series seems to play down the importance of this structural change and I am strongly suggesting that more attention should be given as to why the regulators are allowing the two banks to take such a huge step backwards. It was just a few years ago, that DTC had applied for another rule change that would have allowed the buyside Money market funds to join GCF with special membership status that would not require them to be mutualized. This rule change offered the opportunity to structurally change the workings of try-party repo market by deemphasizing the conflicted nature of the two clearing banks. The evolution of the repo markets. Dodd-Frank mandate CCP clearing of OTC derivatives but failed to consider the same solution for an even more vulnerable repo market. Repo markets have to evolve a CCP structure like the early solution of GCF repo represents. During the crisis, the two clearing banks risk managed their daylight overdraft exposures with the Fed at the cost of the various members who became hostages of the two clearing banks. One could say that liquidity for Countrywide, Bear Sterns, Lehman and MF Global was affected by the two clearing banks further exasperating the crisis. The repo markets need DTC, as a utility, to develop a CCP structure that can act as a neutral risk manager and protect the various members. The repo markets are shrinking and the weight of the regulations like the SLR will continue to affect the liquidity of the markets as was stated by NY Fed Presidents Bill Dudley in yesterday's speech in Atlanta. The Fed needs to act more forcibly to ensure that a new structure develops that can create a CCP for the repo markets or we will continue to see the market move into less stable hands of the shadow banking system. The Fed should not wait for the "street" for these forward looking solutions as they just want to protect their business models. The Fed must realize that we need structural changes in the way we clear securities and that the two bank clearing model is a too big to fail issue given the concentration of tai-party at the BNY Mellon. In the speech yesterday, President Dudley boldly stated that we need clarity of the Fed's Lender of Last of Last Resort language which was a bold statement for a Fed official. The Fed should be equally involved in developing a new structural change in a CCP clearing structure that would envision providing LOLR support to such a CCP. The Fed needs to lead the markets with a solution and while TMPG did decidedly lower the DOD by the two banks this was a behavioral change and not a structural one and could quickly reappear should a major credit event develop. It is time for the Fed to take the lead on the reform of repo clearing because the stakes are too large.