The new proposed reporting requirements are part of a torrent of rule proposals by the SEC, many of which impose very extensive informational requirements. For example, the SEC has proposed to (i) , (ii) , (iii) , and (iv) .

The SEC has generally provided a very limited comment period for each of these rule proposals. (See,  (Statement by SEC Commissioner Peirce)).  

In general, the SEC's justification for the rule proposals is that information is good. Commenters on…

Both the banking regulators and the futures regulators are actively engaged in considering how their regulations should apply to digital assets. (Substantial praise is due in this regard to former CFTC Commissioner J. Christopher Giancarlo.)

The SEC remains the recalcitrant regulator in this regard. Of course, digital assets should not entirely escape the securities laws; there is a need for investor protection. Likewise, the notion that there should be a single new regulator for all…

Form PF provides little, if any, useful information. Rather than expand it, the SEC should explain what it believes it has learned from Form PF filings.

The firms were all charged with very straightforward violations, such as failure to file. None of the violations was based on the substance of the reports.