Governor Bowman has been a consistent critic of stodgy regulation, over-regulation and misplaced regulatory priorities. Philosophically, or perhaps temperamentally, she seems almost the opposite of the former Vice Chair for Supervision, whose public statements were almost entirely focused on every type of risk. (See, e.g. .)

For those who are open to a re-examination of the status quo, there could not be a better choice for Vice Chair of Supervision than Ms. Bowman.  

Acting Chair Uyeda is spot-on in focusing on the rulemaking process. Many of the substantive problems in the rulemaking regime of the former Administration (including its numerous defeats in the courts for either exceeding it legislative authority or failing to comply with the Administrative Procedure Act) arose because it rushed through rules and ignored public comments. (Here's one example: .)

In , FINRA said that there were "longstanding questions" on outside business activity dating back to 2017 and 2018 (see,  and ). Although the proposed changes seemed to have received generally positive reviews, FINRA opted to let the issue sit for six years without follow through. It is likely that FINRA's revival of the issue reflects the Trump-effect change in regulatory culture. It is notable that the impact extends beyond governmental agencies to self-regulatory organizations.…

The no-action letter refers to an "issuer" relying on a minimum investment amount. There is no obvious reason why a broker-dealer should not likewise be able to rely.