Failure of the Clearinghouse: Dodd-Frank’s Fatal Flaw? By Stephen J. Lubben October 9, 2015 by ilyabeylin As is well known, a key feature of the Dodd-Frank Act is the effort to treat swaps more like commodities. In particular, large categories of swaps are to be centrally cleared, replacing the pre-Lehman OTC model with a commodities model …