This was not a gently worded letter. It basically states that the premises of Mr. Barr's remarks were completely incorrect. Putting Mr. Barr's description of the plan as resulting from a "holistic review" in quotes, the letter came about as close to being completely dismissive as one is likely to see in a comment letter to the regulators.

One wonders how the recent bank failures will impact the politics of the proposal. Those failures -- caused by poor management at the individual…

The judge's decision is both dissatisfying and satisfying.

The conclusion that employees have not contributed value in exchange for their non-USD cash consideration (i.e., XRP) is dissatisfying. And plainly wrong. One does not have to be a Marxist or accept the labor theory of value to believe that work is of economic worth and that an asset can be purchased with labor just as it can be purchased with fiat currency. Likewise, the conclusion that the Ripple insiders did not aid…

If Ms Minow was correct that ESG-focused proxies are driven by financial considerations then (i) there should be no reason to lower the eligibility requirements to advocate for proxies since large shareholders would have an interest in pushing ESG priorities and (ii) there would be no reason to allow proxies on matters not related to the main business of the company, since proxies on matters of social policy that are not related to the business of the company by definition are not driven by…

It is generally good business practice for firms to do a daily Rule 15c3-3 calculation because, as the SEC points out, it ensures that the amount of cash that a broker-dealer locks up is consistent with the amount of cash that it receives from customers. While the SEC worries about too little cash being locked up, it is equally the case that broker-dealers benefit from being able to withdraw cash from the reserve account when their customer balances are declining.