"120 priority data elements"? Does that mean there are 1,200 or 12,000 non-priority data elements? Perhaps the CFTC should describe why the information required for each of those elements is important to the CFTC, how it is to be used, and why it is worth the bother of collecting for market participants or the regulators.

As noted in a recent newsletter,  praised CFTC staff members for coming up with the new data requirements while holed up in the CFTC's "war room." Her language seems odd because it appeared to advocate a regulatory philosophy that distanced regulators from the markets that they regulated and darkened their view of those markets. By contrast, market participants who were surveyed in Mr. Sodergreen's article seemed skeptical of the rule, though they did agree with…

Commissioner Stein's underlying preference for more regulation is the common thread throughout her remarks. It is implicit in, for example, her comments as to the private/public market divide, where she questions the "hype" that surrounds private companies. Her questions always point in the same predictable direction: where can we impose more regulation? Can we impose it on ETFs? Can we impose it on swap dealers, on trading markets, on capital raising?

Regulators should…

Investor Advocate Fleming's conclusion is based on the premise that investors benefit from higher listing standards, i.e., an organized market in which there are fewer securities available to trade. For Mr. Fleming to support this negative conclusion, he should be able to demonstrate that the securities that the NYSE has not allowed to list as a result of the new standards have: (i) been the subject of a disproportionate amount of internal fraud, (ii) materially…