This would be a small but significant move away from Regulation NMS, one of the consequences of which was to foster a proliferation of exchanges that had no material trading volume and that essentially survived by the fee-sharing among exchanges. If this request is approved, the SEC should look at the issue of market fragmentation more generally.

While one can be sympathetic to Commissioner Behnam's skepticism of the need for regulatory change, and that such change itself can be costly, sufficient time has now passed since Dodd-Frank was adopted to evaluate many of the rule changes. Many of the rule changes have not only not produced the suggested benefits, but have had a negative impact on liquidity, have increased market fragmentation, and have materially increased costs to end users. Particularly given the tremendous speed with…

This initiative is not just about supervision of bad actors, but also about discouraging firms from hiring them in the first place. To what extent should a complaint or an unresolved complaint taint an individual? That is a difficult policy question.

Ms. Blass expresses support for both the concept of "full-service" brokerage, where broker-dealers are able to make recommendations to retail investors and be paid through trading commissions, and for the imposition of a higher duty on broker-dealers under newly proposed Regulation Best Interest. Two fundamental questions are: (i) how much time/money must a broker-dealer invest in learning about a client so that it would be in a position to satisfy its proposed best interest obligation, and…