Compliance officers should promptly consider how to build the new requirements into their existing procedures, including obtaining periodic representations from registered persons on their credit relationships, and reviewing the process for approving or disapproving any new or amended credit relationships.  

Firms may also want to consider whether their revised processes should include questions that go beyond borrowing and lending, for example, asking whether a registered…

Chair Gensler generally equates more regulation with progress.  

Take, for example, Mr. Gensler's comments on the new rules on short selling and securities borrowing. No doubt, these rules will result in more data. But the information provided is not "free." Instead of information that was obtainable through paid subscriptions, the government is now mandating a massively expensive information collection project to be "paid for" by all market participants. One may reasonably guess…

SEC Commissioner Peirce proposed that advisers to passive funds be required to vote with management, given that the entire concept of passive funds is to follow the market, not make investment decisions or provide direction. This concept is consistent with the CFPB Chair's comments.  

Another similar approach would be to require that advisers to passive funds be deemed to vote proportionately to all investors, as requiring them to vote along side management could effectively…

It is ironic that the US Government touts the benefits of AI for use by the Government, while setting an impossible standard (full explainability) for regulated institutions that seek to use AI.