The SEC's custody proposal is particularly troubling. It would be impractically expensive or operationally impossible for many products. The major question raised is not whether the proposal is a good idea; the real question is whether the SEC has a good handle of how settlement and custody work in products other than the reasonably plain vanilla.  

In the ordinary course, trade associations and financial institutions are fearful of challenging the SEC even when it arguably…

In case you missed it, here is the , starring Mila Kunis, Jane Fonda and Ashton Kutcher.  

The concept seems understandable, but the SEC should provide some further explanation of the specific violations by each adviser.  

It is notable that Mr. Chopra's remarks were issued contemporaneously with a federal  Mr. Chopra's argument comes down to the ends justify the means. He apparently believes that the CFPB is doing good things, and, therefore, it does not matter whether the agency operates in a legitimate manner or is funded through Constitutional means.  

As a starting matter, government officials need to operate within their statutory confines. Contrary to Mr. Chopra's trepidations…