For the CFTC to look at the quality of the data that it requires is certainly to the good. The reality is that the financial industry spent huge amounts of money complying with requirements to provide useless information to regulators. The financial regulators, and not only the CFTC, should (i) determine which information is useful among themselves, (ii) identify the most efficient way to obtain that information and (iii) agree not to impose any information requirements on the industry until…

The major "finding" of the report is that investors who trade frequently receive better dealers' prices than investors who trade infrequently. In short, dealers tend to favor better customers. This idea is neither wrong nor unexpected. What business doesn't favor its larger and more loyal customers?

The most interesting finding of the report is that smaller customers can receive better prices by trading with fewer dealers; i.e., smaller customers do better when they become the…

This study contains interesting information and Senator Warren should be commended for making substantive arguments in support of the DOL's proposed fiduciary rule.

The Senator should release the underlying data of her report to the public to provide added support for her arguments and to allow academics and other interested parties to review her conclusions. One flaw in the report, at least in terms of entering into a genuine discussion of the issues, is that it is intended to be…

Big firms should find that they are already in compliance, other than the necessity of revising their official compliance manuals to incorporate the NFA's express requirements. Small firms, however, are likely to struggle with many of the suggestions that are (bullet-pointed) in Notice I-15-23. This new set of requirements provides a counterweight to SEC Commissioner Aguilar's concerns as to the difficulties that small businesses face in avoiding becoming victims of cybercrimes. On…