This is an odd response to the legislators' questions. GAO does not seem to have performed any independent investigation as to whether the SEC procedures were sufficient to meet the relevant legal obligations in practice. GAO found that a number of certain administrative law requirements do not apply to the SEC as an independent agency, not really a question in doubt. Beyond that, GAO merely concludes that the SEC's adopting release recites that the SEC complied with the administrative law…

For 50 years, Exchange Act Rule 15c2-11 (the "Rule") was understood to apply only to equity securities. The SEC then issued a surprising and seemingly impractical (albeit literal) interpretation of the Rule saying that it now also considered it applicable to fixed-income securities. Having caused a good deal of consternation in the market, from all parties – sell side, buy side, issuers and investors – the SEC then issued a , and a further delaying order, and now the SEC issues a partial…

It is hard to know what to do with advice that banks should create "heat maps" and "climate risk dashboards" when the inputs cannot be quantified and are not agreed upon. Perhaps another way of approaching the issue is to say that banks must manage certain political risk. That is, the risk of laws and regulations changing to promote or disfavor certain industries, whether the industry is energy products or housing or pharmaceuticals.  

There is also the issue of how this guidance…

It is possible to take an alternative view on both the recordkeeping issue and the crypto issue, even accepting that in both cases there are violations of law.

As to recordkeeping, there are instances where the technology for communications ran ahead of the technology for recordkeeping. While firms were deservedly sanctioned for the violations, the penalties seemed disproportionate to those violations.

As to the crypto space, there is no doubt significant amounts of fraud and…