This is the second time that FINRA delayed the implementation of the Debt Research Rule. The delay suggests that firms are facing challenges as they address the requirements of the Rule.

Firms should provide standardized educational documents to their retail clients that would clarify the mechanics and limitations of various types of orders, as well as the possible results of those orders in a volatile market.

To allow firms to publish research reports on open-end companies seems to make good sense even if the firms are participating in the distribution of the same companies' shares. Both Congress and the SEC should be looking for ways to ease the restrictions of regulations governing the production of investment research, since research provides real public benefits even in instances involving conflicts of interest.

That said, this bill is an example of Congress becoming too prescriptive…

Mr. Deas, the representative of a large coalition of end users of derivatives, argues that capital and margin regulations raise end users' costs. His statement provides a clear description of how costs imposed on "Wall Street" (financial market intermediaries) affect "Main Street" (commercial entities).

By contrast, Mr. Gellasch, a lawyer and executive director at a public interest advocacy group, asserts that the end users have not been injured. Mr. Gellasch's position is that…