This is a serious attempt at establishing a framework for the trading of digital assets. The fact that it is largely a voluntary regulatory scheme makes it particularly attractive as it affords the government an opportunity to demonstrate that federal regulation can bring benefits to the table in support of a market (one of those benefits is the avoidance of state money service business regulations).

Of course, there are still many points that would need to be fleshed out. It is not…

Paragraph 65 of the guidance is titled "Reputational Risk." It reads as follows:

“Insurers should consider the negative publicity that may be triggered by insurers' underwriting or investing in sectors perceived as contributing to climate change. This is exemplified by social movements calling for divestment from fossil fuels and the cessation of underwriting of coal-fired power infrastructure. Furthermore, to the extent that individual insurers respond to…

This should serve as a warning to associated persons to keep their Forms U4 current, even as to matters that do not relate directly to securities activities. In this case, the information was potentially significant as it indicated that the individual may have been in financial distress, which could be a red flag for the compliance department to monitor the conduct of the individual more closely.

The inability to count unsecured syndicate profits from an underwriting as good capital works a hardship on smaller firms that participated in the underwriting.