This is a good idea. It is also an illustration of how the SEC should be approaching rulemaking in an area as complicated as the trading of equity securities: don't just do something, test out a concept where it is possible to do so.

Securities firms would benefit from a common framework as to how to handle dealings with senior investors. On the one hand, firms must recognize that they face material liability in facilitating risky investments by seniors. On the other hand, many seniors are perfectly capable, control a lot of wealth, and have long investment horizons.

At a minimum, this means that firms need to be very cautious as to situations in which they may be deemed to exercise discretion or material…

Is this an example of a situation where over-regulation of small banks ended up chasing business away from the regulated sector? Or was the move from regulated bank lenders to non-regulated lenders inevitable given the costs of regulation at any level?