This rule would be expensive to implement and would likely drive many participants from the market. Aspects of it are impractical and inconsistent with the mechanics of the securities lending business, most notably the 15-minute reporting requirement. Yet the SEC would give only a 30-day comment period that includes the holidays, and runs contemporaneously with other major rulemakings.

This is not a case where there is a current emergency or financial crisis that may provide a…

While most of these changes are formalizations of existing law or practice, firms should take the opportunity presented by this proposal to review all of their practices with respect to the sending of customer statements.

This exemption is relevant to other retail-oriented, bank-affiliated broker-dealers, the primary credit activity of which is lending under margin agreements.

Last week, the SEC the listing application of two ETFS tracking the performance of Bitcoin based on the view that the ETFs did not satisfy various listing requirements under Section 6 of the Exchange Act that are intended to ensure fair pricing. Given the SEC's objections to those ETFs, it is not clear on what basis the SEC might warm up to a carbon-neutral ETF.