Chair Clayton points out in his remarks that raising money for small businesses is not big business. The costs and registration requirements can be onerous.

It is not obvious that deregistration, rather than registration-lite, is the best answer, but it would seem to provide more potential for helping small businesses than the current regime. The real outcome of deregistration at the federal level would likely be to kick the decision to require registration down to the state level.…

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Secondly, if this works out reasonably well for the two-year period, regulators will need to give serious consideration as to extending the relief permanently, even if the virus has ceased to be a material threat. See also .

The CFPB's letter provides that the no-action position is available only to Bank of America and not to any other persons. This is consistent with the by Chair Heath P. Tarbert of the CFTC that a regulatory agency's no-action position should be specific to an individual entity.

The policy basis for this approach to no-action positions is not obvious. As a general matter, the law should be the same for everyone. Here is a suggestion: perhaps anyone else relying on the letter should be…

It is now generally understood that even if the virus were to disappear tomorrow, the work world would not return to its pre-COVID 19 state. Many workers have discovered that they can do their jobs successfully without going to the office five days a week; many businesses have discovered they don't need quite so much expensive real estate. The question now is how quickly will the SEC acknowledge that reality?