Author Archives: Ryan Clements

Non-Intermediate Clearing of Crypto Derivatives on Margin is a Bad Idea

By | May 12, 2022

The following is an edited comment letter that was submitted to the Commodity Futures Trading Commission (CFTC, or Commission) on May 11th in regards to the Commission’s request for comment on FTX’s request to amend their derivatives clearing organization order to permit it to clear non-intermediated, margined products. All submitted comments can be viewed here. We are law professors… Read More »

ESG ETFs and the Costs of Information Synthesis

By | October 4, 2021

            Despite likely being the most successful investment product since the 2008 global financial crisis, exchange traded funds (ETFs) have a serious comparability problem. The problem is particularly acute in environmental, social, and governance (ESG) themed funds, which have benefited from a recent surge in investor interest. A post-crisis explosion in ETF product offerings, combined with extensive issuer discretion in the composition, replication and tracking… Read More »