Based on the public press release and comments, this proposal seems to unduly elevate procedural issues over substantive ones. (Note the proposal is not yet available on the SEC's website.)

Having one market system plan rather than three is not going to change the reality that the exchanges and the broker-dealers have interests that are fundamentally adverse to one another: each wants to "own" as much data (intellectual property) as possible, give away as little data as possible, and…

Anyone involved in the development and maintenance of a compliance and supervisory program should review the entire report for the guidance it provides on OCIE's examination focus.

The report provides some interesting statistics on the growth of the investment adviser industry. The number of broker-dealers continues to decline. The number of advisers continues to rise. There is good reason to believe that that trend will continue and, with the implementation of Regulation Best…

The competition among the states to outdo the federal government - and each other - in promulgating rules to protect financial consumers will have real economic consequences.

The likely result is increased pressure on the "full service" broker-dealer models, where broker-dealers provide both investment recommendations and trade execution to customers. See, e.g., . For customers that do not want to pay - or do not have sufficient assets to pay - an assets under management fee, this…

Yet another illustration of the fact that when something goes wrong with technology, the number of violations could get very big, very fast.