The DSIO has issued a series of virtually identical no-action Letters granting relief from the common control requirement of CFTC Letter 14-126. In the new age of regulatory efficiency, DSIO should consider issuing an interpretive letter dispensing with the common control requirement, thereby relieving firms, and the CFTC itself, from having to go through the no-action process.

The MSRB's statement provides a useful outline for firms to undertake a general review of their compliance procedures in this space. There is nothing like a priority risk list from the regulators to focus one's attention.

There are few policy decisions that are as significant for a regulatory agency as determining how to handle firms and individuals that come forward with admissions of their own legal violations. It often seems to outside observers that the desire of regulators to chalk up an easy win, or to be acclaimed for collecting a fine, overwhelms any inklings of common sense (or compassion). This is unfortunate because when a firm comes forward, particularly with information as to unintended…

Given the absence of any specific requirements as to how the compensation calculation should be made and the complete absence of any reasonable policy rationale for this rule (after all, the CEO's salary is disclosed), issuers have significant flexibility as to how to comply with this rule. Don't waste resources overthinking the reporting methodology. The important compliance rules are (i) choose a methodology (doesn't really matter what it is), (ii) fully document it,…