This proposal is a large step in the right direction of reforming FSOC. The notion that the government could, on the basis of an almost entirely discretionary and non-transparent set of procedures, impose an open-ended set of requirements on individual companies is fundamentally inconsistent with the notion of the "rule of law."

Currently, there are . No such arbitrary individual company designations should be made again. Congress would do well to eliminate this arbitrary…

Commissioner Peirce is a champion of intellectual and political freedom because she is not merely smart and funny; she has the courage not to be cowed by the going view of what is a correct opinion or the pretense that good corporate governance is a synonym for obeisance to trending moral platitudes. See ; ; . See also Matt Levine's piece, .

Every year, the vast majority of NASAA's proposals relate to the strengthening of enforcement mechanisms. By contrast a relatively small percentage relate to measures that might, for example, encourage capital formation within a state. Is that because state securities laws are not tough enough? Or is it because the natural inclination of securities regulators is to focus on enforcement rather than economic growth?

Under current Sanctions Guidelines, the number of violations that the regulators can find when a firm does not trade report correctly is astronomic. Here, a small firm was found to have committed almost a half a million violations. While the amount of fines levied by FINRA in this case seems modest, under the Sanctions Guidelines, FINRA has the power to assess an amount based on each failure to report as a separate violation. Perhaps the Sanctions Guidelines should be revisited so…