The FRB penalty raises the often-repeated question as to the purpose of money fines in situations like this. As a result of its poor risk management the bank (Credit Suisse) lost $5.5 billion and was forced to be acquired by another bank (UBS). Presumably, the responsible individuals have lost their jobs. One can certainly see the benefits of a study and disclosure of what went wrong. But it's hard to see the purpose of the fine. After all, the bank lost a boatload of money and no longer…

Presumably, the banking regulators are paying a good bit more attention to reports of uninsured deposits in the wake of recent bank failures. Such deposits may be expected to flee very quickly in the case of a negative news event as to the relevant bank.  

What a complicated piece of legislation this is! It may be even more complicated than the regulation of swaps and security-based swaps under Title VII of Dodd-Frank. While the definition of "swap" under Dodd-Frank is arguably imprecise and overly broad, at least there was a pre-existing consensus as to what a swap is - and that consensus has largely governed conduct in the market, perhaps more than the definition in Dodd-Frank. In the case of digital assets that may or may not be securities…

It will be interesting to see whether Chair Gensler can receive bipartisan support for an increase in the SEC's budget given (i) that significant aspects of the Chair's rulemaking agenda  and (ii) the heavy criticism for the SEC's . (Not to mention, some  of his agenda by his fellow Commissioners.)