As Mr. Atkins points out, there are many good reasons for the DOL to delay the implementation of the fiduciary rule, including the current legal challenge before the U.S Court of Appeals for the Fifth Circuit, and the debatable assertion of "$17 billion" in savings made in a 2015 Council of Economic Advisers' Report supporting the adoption of the rule. Further, the existence of two regulators, the DOL and the SEC, that each have independent suitability rules…

Any firm touching penny stock activities should be particularly mindful of the quality of its AML procedures (and of the need to strictly follow those procedures).

Whatever one thinks of the appropriate standards of conduct that should apply to broker-dealers and investment advisers doing business with retail investors, it is simply an absurd notion that the Department of Labor should set one standard for conduct as to certain assets and the SEC should simultaneously set general standards of conduct. Congress should direct that standard-setting as to retail securities transactions is within the exclusive purview of the SEC.

Few things are more dangerous to financial institutions than rogue employees. For example, cost Société Générale approximately 4.9 billion Euros. concealed trading arguably put Kidder Peabody out of business. While the current incident was very small-time by those standards, it should renew the lesson to firms of the importance of closely watching their own traders.