This case puts companies on notice that they need to deal very carefully with the handling of an employee who raises issues internally, even when the issues raised have no basis in fact, and likely even when the employee raises the complaint in an inappropriate manner.  

Neither the Order nor the press release provides sufficient information to gauge the seriousness, or the likely basis, of the particular issues raised by the employee. Given that (1) the company…

Is the compliance burden of tracking minimum increments really worth the rule's benefits (to the extent any such benefits exist)?

Regulators exaggerate the benefits of central clearing despite the following pressing consideration: since short-term interest rate swaps in major currencies are fairly liquid, it is unlikely that central clearing greatly reduces systemic risk. The financial crisis was not caused by interest rate swaps in major currencies. If the mandatory clearing of these swaps offers any benefit whatsoever, it might be the facilitation of trading in the ordinary course, since clearing allows a customer to…

In statements that might have sounded familiar to Goldilocks, the three SEC commissioners voiced three different views on the final rules: Commissioner Stein said that they do too little, but are better than nothing, Commissioner Piwowar complained that they comprise a part of an ill-conceived scheme of regulation that exacerbates the problem of too-big-to-fail, while Chair Mary Jo White declared that the rules are just right.