The Clarity Act is not considered completely dead after failing a procedural vote in the Senate, but JPMorgan analysts say the opportunity for passage before the current Congress adjourns for its year-end recess is extremely limited. They expect attention to move toward rulemaking by the SEC (U.S. securities regulator) and CFTC (U.S. derivatives regulator), while cautioning that agency rules generally have less durability than legislation enacted by Congress.