Commissioner Bowen's warning that a single country's regulators should not go it alone is true. The comment might best be directed at her own agency, the CFTC. There is no other regulator whose conduct has made it such an obvious target of her warning.

This enforcement action reminds broker-dealers to continually review the effectiveness of their current compliance checks and exception reports. In particular, it is incumbent upon the firm to take the time necessary to review internal control procedures to determine whether an order should have been stopped before it hit the market.

It is noteworthy that SEC Chair White links the SEC's "modernization" of the regulation of the asset management industry to systemic risk. The idea that the SEC should regulate the asset management industry to protect clients is obvious; likewise, that the SEC should regulate the industry to prevent any trading or investment misconduct of advisers from injuring third party market participants is obvious. That the SEC should be regulating investment advisers so as to limit systemic risk is…