Why is the SEC merely warning retail investors about IEOs instead of asking them to contact the SEC or a state securities regulator? Here, for example, is a touting IEOs and purporting to distinguish them from initial coin offerings that are securities. The author makes it fairly clear that the exchange through which the IEO is offered is acting as a broker-dealer or underwriter.

Several of the financial management areas of focus are as to issues where there is not actually a rule in place; e.g., liquidity management and transition from LIBOR. That does not make them any less significant. Firms may want to consider how they institute operational procedures to deal with regulatory expectations where there is not a specific rule that drives the firm's conduct.

As NYDFS launches this new initiative to protect consumers, New York officials might want to consider additional ways to improve the business climate in the state. A quick web search turns up (i) a in terms of its policy environment for small businesses. which ranks New York much higher (28th) for business overall only ranks it 37th for regulatory environment. While New York has numerous historical advantages in maintaining its standing as a desirable place to live, the world changes: and…

ESG is a broad and open-ended concept which provokes many questions that do not have clear answers. Whose decision is it as to what is "socially" correct? What is the relationship between the manner in which a firm is governed and sustainable finance? Are startups that provide their founders with disproportionate governance influence inherently inconsistent with "sustainable finance?"

As a practical concern, the statement that ESG disclosure is inherently "material" seems an…