question of how you clear and handle the derivatives that might be involved in that institution, the sbaps, is important. i would be curious how you're doing on thinking through that portion of liquidation process. >> i think central clearing does happen that. there is central clearing currently dealer to dealer. so the dealer is facing a hedge fund or not yet in. that will help a lot. we spent a lot of time with the fdic on title two, just to give them advice and thoughts on it. i think the most challenging piece is on the swaps not clear ch they still leave a tangled web of interconnectiveness. that's why it's clear to get the margin rules right. between the financial institutions and particularly between the dealers. >> both fdic and the fed on this? >> yes. and we've had the table tops where we take hypothetical, not a real company, but sort of think it through. there is a challenge in one provision with the unclear swaps. we worked on that. >> very much. >> what uncertainty would be in the market. it seems everything is challenging to get it done before japan or australia opens, which

under the dodd-frank act regulatory authority over sbaps is divided between the cftc and the commission. the law signs the sec the authority to regulate security based swaps while the cftc is primary regulatory authority over the bulk of the title 7 over-the-counter derivitives markets called swaps. our rule makes are designed to reduce transparency, facilitate the centralized clearing of security based swaps to reduce counter party risk. they're also designed to enhance investor protection by increasing disclosure regarding security based swap transactions and mitigating conflicts of interest. by promoting transparency, efficiency and stability, this framework is intended to foster a more stable and competitive market. in implementing title 7 sec staff is in regular contact with the staffs of the cftc, the if early reserve board and other financial regulators. in particular, commission staff is coordinated extensively with cftc staff in the development of the definitional rules including joint rules for the defining key product terms which we expect to finalize soon and rules further d