Always Crashing in the Same Car—Clearinghouse Rescue in the United States under Dodd–Frank

ABSTRACT Clearinghouses are central to our financial system after Dodd–Frank. And they will remain central even if Dodd–Frank is repealed. But clearinghouses themselves are apt to be quite fragile in times of extreme financial stress, like that experienced in 2008. And strangely Dodd–Frank only addresses clearinghouse resilience in the most oblique manner. In this article, I suggest additional steps that can be taken to make sure that clearinghouses perform their role in the financial system, and thus avoid becoming the next ‘too big to fail’ institution in need of a bailout.