To reiterate Mr. Atkins' remarks, there is simply no ethical justification for the level of fines that the SEC imposed on broker-dealers for recordkeeping failures that were not connected to any injury to customers or to a conscious attempt to hide information from the regulators. The fines were simply a raw exercise of power, which also allowed the SEC to boast in the press as to its prowess in collecting fines.

This is not just a bank issue. It is a US government issue. If US capital regulations applicable to banks make it unduly expensive for banks to hold positions in US governments, or to finance customer positions in US governments, that makes it more expensive to transact in US governments. In turn, that means that the US government must pay a higher interest rate to induce investors to hold its securities, which drives up the cost of financing the US government's very substantial debt. …

While there are no doubt benefits to allowing at least indirect retail participation in private issuers, there should not be any neglect of the tasks of re-examining the regulations imposed on public companies. One reason why more issuers stay private is that going public costs more than the benefits it provides.  

Since its adoption, Form PF has been an exemplar of ill-considered information-gathering requirements by the government. (See, e.g.,  (July 31, 2013)).

Before adding the new requirements, the regulators should provide a clear explanation of just what value it is that they derive from the Form. It should have been obvious from the time of the Form's adoption, that pretty much all of the questions were so poorly drafted that there could be no other result than GIGO. …