There is interesting data contained in this report, particularly as to the regulatory costs that unfairly burden small public companies. While the SEC regularly says nice things about the importance of small businesses, these statements are seldom backed up by regulatory action. To the extent that the SEC has taken any actions to support small issuers, these are actions that have been directly mandated by Congress, such as Regulation Crowdfunding.  

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The ineligibility provisions of U.S. financial regulations are broad. It is often difficult for firms to keep track of the fact that violations as to a limited activity may disqualify the firm from wholly unrelated activities unless a waiver is obtained.

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There is a lot of complexity, uncertainty and risk associated with these new requirements. Here are a few compliance concerns and policy questions: 

In a year when major bank failures were caused by basic risk management deficiencies, the report might have been of more value if it focused on the financial risk from mismatches in the funding of assets and liabilities, which ultimately cost billions of dollars and essentially forced the FDIC to guarantee the deposits of every bank in the United States, rather than on all the effort apparently undertaken to work on climate-related financial risk.  

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