Can anyone demonstrate that sustainability disclosures that were not material to an issuer's investors have created some desired and long-term change in behavior? As Commissioner Uyeda indicates, if it is desirable to have a change in environmental conduct, that change should be driven by Congress and the environmental regulators. Forcing issuers to make disclosures of issues that are not relevant to investors is more likely to discourage issuers from going public than they are to change…

It is an unfortunately political reality that regulators may use high numbers of enforcement actions and penalty amounts as a metric for success. But is it? Perhaps economic growth and clarity of rules are better metrics, even if they are less amenable to press releases.  

If U.S. regulators continue to push rules (capital and clearing requirements) that make it more expensive to hold, finance and trade U.S. Government Securities, they will discourage financing institutions and investors from holding those securities, or at least drive up the interest rate that must be paid on those securities to attract buyers. As the amount of government debt grows with no political will to constrain that growth, regulatory policy that makes it more expensive for banks to…

To a good extent, Mr. Barr's remarks reflect the significant difference in regulatory approaches under the Biden Administration and the Trump Administration. Mr. Barr’s approach would have one believe that, unless there is significant ongoing and additional investment in more regulation, supervision and enforcement, very bad things will happen that the regulators would otherwise have prevented. Mr. Barr's approach may be reasonably compared to that of former SEC Chair Gensler, while the…