This paper looks at Global Systemically Important Financial Institutions (GSIFIs) and the global derivatives business. The derivatives business has grown exponentially versus global GDP in sharp contrast to the primary securities on which derivatives are based. Inter-connectedness risk and unconstrained potential leverage remain the most urgent tasks still facing the financial reform process. Concentrated oligopolistic derivatives markets and the ability of banks to shift promises and/or use their IRB models to estimate ex-ante risk capital – capital that might be needed in the event of a crisis – undermine the intent of financial reform. Nor do netting and clearing eliminate aggregate risk of losses and bankruptcy. The paper repeats the need to implement two of the OECD’s long-standing reform recommendations: a binding leverage ratio based on equity and the separation of high risk investment banking activities from traditional banking. A derivatives transactions tax is also put forward as a possible option that would counter the cross-subsidisation of risk from the too-big-to-fail (TBTF) problem.