The proposed IEX exchange was made famous by the book Flash Boys, which attempted to beatify its founders by demonizing everyone else. Now that IEX has put forward a formal proposal, it will be interesting to see how the SEC reacts to a set of exchange rules that (at least in the view of FIA) do not conform to the automation requirements of Regulation NMS.

It is good to disclose information about bad guys quickly. The question is whether accused employees have enough opportunity to rebut any negative statements made about them. Establishing a balance between these two concerns is not easy, but employees' rights and concerns should be given more attention under current practice.

Advisers should review Chapter 5 of the standards, since it is applicable to them, and consider which of the proposals are most practical to implement. 

Commissioner Stein makes two disparate observations:

"Why has the asset management industry in this country remained so competitive? There are many reasons, of course. But I believe that chief among them, as I have noted throughout my talk tonight, is that investors have faith in the quality of the product. Although they may not know it, investors are protected by a law called the Investment Company Act of 1940, which ensures that there are basic rules of the road that make these…