This is not as simple a matter as Commissioner Crenshaw suggests. To appreciate the substance of the debate, it is necessary to read not only Commissioner Crenshaw's dissent from the dismissals of these actions by the current SEC, but also from the enforcement actions previously brought by the SEC under the former Chair.

Commissioner Crenshaw likens the dismissal of these enforcement actions on convertible bonds to the SEC's dismissal of enforcement actions brought against entities…

The factors proposed by Commissioner Goldsmith Romero line up imperfectly with the put forward by CFTC Acting Chair Pham. However, the proposals are not inherently inconsistent. Unfortunately, during a period of transition of Commissioners at the CFTC, there will not be an opportunity for resolution of any differences or for amplification of places of agreement.  

FINRA had previously brought when they left their firms. This is a reversed fact situation, a broker-dealer fined for failing to keep its customer information from departing representatives.  

It is hard to dispute that rapidly expanding US government debt is anything other than terrible for the US economy in the near-immediate term. On the other hand, there seems zero political appetite or willingness by either party to take actions that would reduce the deficit. Accordingly, it would seem inevitable that the bank regulators must eliminate or substantially modify the Supplement Leverage Ratio so that banking organizations can hold more US government securities on their books.…