While regulators might obtain some benefit through the centralization of information provided by CAT, it is unclear how that benefit can be sufficient to outweigh the risks of centralizing so much financial information about so many individuals. If regulators worry about "too big to fail," isn't it just as sensible to worry about "too much data to store in one place"?

From a financial policy standpoint, the SEC's renewed focus on its traditional economic missions (good disclosure, investor protection) is an important change in priorities. When combined with a rulemaking agenda that is limited to achievable and announced goals, businesses are better able to prepare.

Not so long ago, CFTC Commissioners were imagining the adoption of U.S. regulations that would have required the rest of the world to acquiesce. . The current Chair is now left to see if peace can be made.

The SEC has technology that is on the lookout for Regulation M short selling violations. Any adviser that is not attending to this issue needs to pay more attention, particularly given the reality that it is the adviser and not the client who disgorges.