While this report may be of primary interest to those providing services to investment advisers, it should be valuable for regulators as well. The report offers a realistic understanding of the industry that they are regulating. The report demonstrates that most of the regulation of investment advisers is, as a practical matter, the regulation of small businesses, and, therefore, the requirements that fall on the majority of advisers should be tailored towards small businesses. Perhaps…

EB-5 investments seem to attract fraud at an unduly high rate. This is an issue worth attention because the victims of such fraud are not only the defrauded investors, but also the United States, which essentially is offering an opportunity to reside in the United States for immigrants who are able to provide investments that strengthen our economy. If those investments themselves are fraudulent, the country loses the benefit for which it has traded residency. See .…

According to the SEC, amendments requiring additional financial data about managed accounts will provide more information to investors and regulators, and will help regulators understand the economy better. The SEC claims that the new requirements are modeled on those in Form PF. That is most unfortunate. As noted in the past, Form PF is poorly designed. Many of the questions in the form generate little useful information. In fact, Form PF is so flawed that even the Office of Financial…

Although Regulation S-K disclosure is not inherently political, it has become a political topic in today's environment. The question is whether the  are intended to (i) help investors make investment decisions or (ii) advance goals that are not relevant to the SEC's mission as defined by the Securities Exchange Act.