Commissioner Lee states: "When we relax or repeal certain of these laws or regulations, [we . . . ] alter incentives and magnify the force and impact of the remaining rules on the books." In other words, expanding exemptions from registration makes it less desirable for an issuer to bear the costs of registering itself or its securities. Ms. Lee views registration as providing a material public benefit, her response to the problem is to restrict exemptions and thereby to force issuers to…

The proposed rule change, combined with FINRA's statement that it expects to import further elements of Regulation NMS into the requirements applicable to the trading of OTC securities, and the to ("Initiation or resumption of quotations without specific information"), indicate that firms involved in the trading of OTC securities should be prepared to dedicate significantly more technology and compliance resources to the business. See also .

Reg. SHO has become so complicated that the policy of the regulation has become almost divorced from and subordinate to the technical requirements of the regulation. If one begins with the policy of the Regulation, that broker-dealers not fail on their delivery obligations, why should it matter that a U.S. firm aggregates the positions and trades of its foreign affiliates, rather than treating each of them separately, so long as, at the end of the day, the firm is able to make deliveries on…

The title of the hearings, "Wall Street's Cop Is Finally Back on the Beat," says it all: financial markets and market participants are bad, and fines are coming.

The individual bills cited seem largely intended to encourage litigation or lay the grounds for enforcement actions.

Whatever problems there may be with SPACs, legislation fixing the "promote" at 5 percent is completely arbitrary and premature. The SEC has plenty of authority to regulate SPACs, and FINRA has plenty of…