Among the more interesting of Mr. Quintenz's comments were to the effect that the developer of a computer code could be held liable for illegal use of the code by other parties where the developer might have been able to foresee such misuse, and even where the developer was not directly involved in such misuse.

The case serves as a reminder that many of the largest frauds at financial institutions have been perpetrated by employees of those institutions. Revisit your internal controls.

The  because the questions are badly drafted; it is likely that the authors of the questions did not fully understand the relevant law or the economics of the subject matter. Undertaking to improve the form by eliminating useless questions essentially means discarding the form as is. If the regulators want to maintain Form PF (or something under that moniker) as a useful document, they are going to have to go back to the beginning and rethink it entirely.

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Commissioner Peirce's arrival at the SEC is genuinely exciting to those who care about financial regulation, both in its implementation and philosophy. She is not just staking out positive positions, which is obviously a nice-to-have; she is establishing the intellectual underpinning of those positions, which is an essential-to-have if the positions are to be enduring and establishing a framework for approaching issues on an ongoing basis. By conceding that there are limits to the knowledge…