The proposed registration regime has the potential to provide financial institutions a great deal more flexibility in moving individuals within a group, without being concerned that the individuals will lose their licenses because not currently active with the broker-dealer.  The proposal will also allow firms more flexibility to have "back-up" personnel who do work for a broker-dealer affiliate, but who can fill in at the broker-dealer if circumstances require.  Firms should…

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The gist of the NASAA recommendations is this: give state regulators greater support and more authority to impose fines. It is not clear what, if anything, the request for improved financial stability means. One interesting recommendation concerns the carve-out for offerings for sophisticated investors. That recommendation seems to call for a decrease in some regulation, though it is hard to say what exactly is being requested.

Commissioner Stein quite rightly raises questions about funding portals. Under the SEC's crowdfunding rules, funding portals are subject to significant restrictions that effectively prevent them from making any money, and also subject them to significant responsibilities in order to prevent others from losing money. Given those limitations and responsibilities, the most likely sorts to take on the funding portal role might be saints and criminals. Given the way that the world tends to…