A separate rule set for CABs is a good idea. The current system of broker-dealer registration and regulation is simply too much for firms that are engaged in limited kinds of securities activities. As a result, firms either must give up on registering, forgo the broker-dealer business, or get hit with excessive regulatory costs. Providing an appropriately tailored form of regulation should boost compliance significantly. When it comes to the details, firms should comment on what works and…

, "The four mainstays of the [Vanuatu] economy are agriculture, tourism, offshore financial services, and " [emphasis supplied].

At last, the CFTC is making meaningful progress in closing the regulatory rift between the United States and the European Union. Such progress is due to the persistence and determination of CFTC Chair Massad who managed to overcome his predecessor's vision of a Europe surrendering to the dominance of U.S. regulation – a vision that failed completely and proved to be a waste of time and energy.

It seems odd to give up on the notion of attempting to quantify the direct costs of regulation, notwithstanding the academics' view that the analysis of the Conflicts Mineral Rule was poorly done. The better approach would be for the SEC to try to understand what it did wrong (or right) in analyzing costs. After all, what reasonable business – or household, for that matter – would give up on the notion of estimating costs simply because it failed to do a good job in particular instances?