This is a useful description of the arbitration process, but it contains a glaring omission. The FINRA rules give customers an absolute right to arbitrate in all events. Thus, even in the absence of an agreement to arbitrate, the customer can force the broker-dealer to arbitrate rather than go to court.

The SEC's description of arbitration agreements reads as if broker-dealers have an unfair advantage over customers in forcing customers to arbitrate. In fact, the FINRA rules give the…

There are two basic types of asset-backed stablecoins: (i) fiat-currency backed; and (ii) securities-backed. The first seems like a straightforward banking product, and the second a money market fund. Banking regulators and the SEC should be able to produce a set of regulations workable for each type.

This enforcement order reminds firms that they cannot rely on outside vendors to ensure that their systems meet regulatory requirements.

As a general matter, the changes would have the effect of potentially driving trades in securities, particularly trades initiated by retail investors, to the national securities exchanges rather than being internalized by a broker-dealer (or sent by the firm receiving the retail order to a market maker that sent "payment for order flow" to the firm that had received the order). 

The question is whether these changes would result in better market prices that are…