These proposed rule amendments take place amid substantial changes the SEC is making in the U.S. government securities markets including proposed requirements on central clearing of certain repo and cash market transactions in U.S. Treasuries.

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It appears that the NYDFS is calling on banks to hire climate consultants to create detailed reports, and then have meetings at which the reports are discussed. Or, to quote the guidance:

"Regulated Organizations [must] build their capacity to assess and manage climate-related financial and operational risks, [but] they may take an iterative approach that leverages further developments in methodologies and improved data availability."

It is not at all…

The SEC's  based on the volume of an entity's trading, and with regard to the manner in which it trades, or the purpose for which it trades, is unprecedented in 90 years of interpretation of the registration requirements of the Securities Exchange Act. It is clearly vulnerable to judicial challenge. That said, it is not even clear that the expanded dealer registration requirement is the SEC Rule that will have the largest (potentially negative?) impact on the market for U.S.…

While the Review does not make recommendations, there is no dispute that the definition of "accredited investor" has become less exclusive or more inclusive, depending on one's viewpoint, since the definition was first adopted.

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