Overlapping, duplicative and confusing regulations imposed by multiple regulators on exactly the same activity is bad public policy.

In light of Mr. Osnato's warning, all firms should make it a priority to conduct an audit of their customer protection rule procedures, including their calculation methodology and procedures for segregating securities.

While the FSOC Report provides good general background on the state of various types of financial institutions; e.g., broker-dealers, credit companies and banks, as well as an overview of regulatory developments, it seems to be at least as much a political document as an analytic one. Very little is said regarding the reasons why FSOC's designation of an insurance company as "systemically important" was rejected by the court, or of the criticisms of the SEC's…

Mr. Barnett's comparison of banking and broker-dealer business models could be interpreted as an implicit challenge to some statements by the Board of Governors of the Federal Reserve and other senior banking regulators, that traditional broker-dealer activities like securities lending should be regulated similarly to bank lending. Mr. Barnett's observations on that subject recall earlier discussions of the differences between banking and securities dealing that were led by former SEC…