The requirement imposed by the prior Administration at the SEC that CAT collect personal data, along with trading data, was reckless. (See .)

Anyone who runs a database that holds customer information knows that the information is both valuable to have and dangerous to hold. It makes the data repository a target for bad actors. Requiring that FINRA hold personal data, in combination with trading data, made FINRA into one of the most valuable targets in the world, for every kind…

In many cases, the penalties imposed on individual brokers who violate their customer obligations seem quite light, relative to the actual or potential harm. Perhaps this individual broker is a wonderful guy and really intended to repay the undocumented borrowing. But the fact that he also has a disciplinary history for suitability violations seems a relevant problematic fact.  

Not all OTC options entered into by a non-U.S. dealer are required to be LOPR reported. Firms must carefully evaluate the manner in which they conduct their sales activities with respect to such options so that such options are appropriately categorized as to whether they are subject to reporting.  

The approach taken by Chair Atkins to reduce the tasks demanded of public issuers - and the expenses of those tasks - runs counter to his predecessor's approach and seems more likely to encourage private issuers to go public.

In considering why issuers did not choose to go public, but instead to rely on the private markets for financing, the former SEC Chair took the view that the reporting burdens imposed on private issuers were insufficient, and if only those burdens were increased,…