Here is the Wikipedia article on a "," a term that sounds even cooler than just a plain old "Letter of Marque." Like many things that seem totally crazy, this probably is not so crazy. According to Wikipedia, the use of the Letters arose in a time when "the ocean was lawless," a description that may not be wholly inapt as applied to criminal enterprise on the internet. Further, it is commonly reported that many cybercrime operations act with at least the tacit support of hostile foreign…

It will be interesting to see if the SEC has an interest in salvaging these rules by attempting the required cost-benefit analysis. Or, as is more likely, the SEC simply abandons them and moves on. The SEC has more important issues on its plate (digital assets, AI, cybersecurity, capital formation, clearing of US governments, CAT) than trying to fix yet another regulatory reporting requirement.

Even if one believed that there was some value to the extra disclosure of securities…

Seems a high fine for a violation that was self-reported and, to the extent possible, corrected.

FINRA should re-examine the internal logic of its fine amounts. In today's newsletter, a bank is fined $500,000 for a SAR reporting failure that was unintentional and self-reported.  

Excessive trading at the level described in the above enforcement actions is not a close call; it is just a form of theft. Two brokers who essentially stole money from their retail customers are fined, respectively, nothing and $10,000. That sends the wrong message.