The IOSCO report is useful insofar as it provides an overview, and some guidance, as to the direction of regulators in various jurisdictions around the world. The report may be particularly useful to firms looking to stay on top of, or ahead of, regulatory developments.

Given the increasing degree of regulatory focus on this area, and the real possibility that regulators and arbitrators may expect firms to have "best practices" in place that go beyond strict legal requirements, firms should develop their compliance procedures as to the treatment of senior citizens. These procedures need not be the same as those put forward by NASAA, but they should reflect each firm's consideration as to what is right for its business.

Commissioner Giancarlo has proven to be a thoughtful regulator concerned with the workings of the markets and, in particular, the viability of small firms. He has also been forward thinking in regard to matters such as cybersecurity, virtual currency and internationalization. See, e.g., ; ; ; .

The Treasury's request for public input follows immediately on the heels of their real-world critique of problems with the current regulatory system (see ). Market participants should take up the Treasury on this request for comment. The new regulators appear to be concerned with real, practical problems, such as duplicate or ambiguous regulatory requirements, regulatory costs, diminished liquidity and market fragmentation.