Banks should be able to, if nothing else, provide custodial services for digital assets. When the Madoff fraud was uncovered, the response of the regulators was not to say that securities activities were risky, and therefore banks should not provide custody as to securities. As to crypto assets, the real risk the bank regulators are imposing on the public is discouraging regulated entities from providing custodial services.

If greenhouse gas reporting goes forward, Commissioner Peirce is likely to look back on these budget increases for audit requirements as the good old days.

NYDFS tries to walk a difficult political line in this guidance. It says that (i) on the one hand, low income communities will be the ones most impacted by climate change, and (ii) on the other hand, banks must not reduce lending to low income communities. What follows from those contradictory statements?

The Small Business Committee can produce recommendations, but they are not meaningful unless the SEC Commissioners are committed to regulations that will benefit small business. This means deregulation, because the most meaningful action the SEC can take is to reduce the regulatory burdens on small business. As illustrated by an exchange among the Commissioners (covered ), the current SEC Chair does not seem amenable. The most small businesses can hope for is that someone at the SEC is…