Proposing major rule changes and allowing only a 30-day comment period is simply inappropriate. This is an entirely separate question from whether the rule is good or bad. Market participants should be entitled to a reasonable amount of time to review a major rule change, consider its implications, gather together as a group, exchange ideas and reactions, and comment. There is no emergency here, just as there is . Part of the regulatory process is having real respect for public comment and…

Form PF is worthless. (See, e.g., ; ; ; ; ; ; ; ; ; ; and so on.)

In the decade since Form PF was required, there has not been a single public report analyzing the data and demonstrating its value. That is not because the data must be kept a secret. Any lawyer knowledgeable about the issues as to which Form PF is intended to elicit information can tell, without seeing the responses, that the questions asked by the report are completely ambiguous and badly stated. There is no way that…

Commissioner Roisman departure is a real loss for the SEC. Commissioner Hester M. Peirce is for now left as the only dissenting voice.

It is notable that the exchanges brought this enforcement action without the involvement of FINRA enforcement staff and that the exchanges collaborated on the action.

As in a press release on the action, the SEC approved in 2019 Nasdaq’s request to conduct investigative and enforcement functions previously performed by FINRA. NYSE its market surveillance, investigation and enforcement role from FINRA in early 2016.

This joint investigation may serve as notice of the exchanges…