It is interesting that a firm's CCO is being disciplined for failing to supervise the CCO's own boss. Given the fact that the firm's president and CCO are married, it's difficult to say how much of a precedent this establishes, if any, but CCOs should be aware that they have upward supervisory obligations.

The FINRA disciplinary action against the firm's owner is a reminder that a supervisor cannot insulate himself from liability by failing to register.

A number of FSOC's suggestions relate to expanded data collection. While "information is good," in theory, data collection is expensive and so much of what Congress and the regulators have mandated to date has been of little value. By way of example, nothing ever came of the requirement that firms report information to the regulators on their pre-Dodd-Frank swaps. Form PF for private advisers has been an extended and expensive exercise in the collection of useless data.