Enforcement penalties such as this one raise the significant question as to who is being punished. Investors who bought stock at an inflated price in reliance on the fraud are now punished again by the loss in value to the issuer.  

Ultimately, the parties that are really at risk if the Treasury Clearing mandate increases the costs of funding U.S. government securities, or results in a reduction in the liquidity of the market, are the U.S. Government and taxpayers, who will bear the increased costs of funding the U.S. Government's debt.

It is absolutely remarkable (and not in a good way) that the U.S. Government, under the prior Administration, failed to realize or to take account that the clearing mandate as…

The Global Research Settlement was imposed about 20 years ago in reaction to findings that investment banks were publishing over-optimistic research on internet startups in order to win investment banking business. The firms made subject to the Settlement were those that were found to have pumped internet issuers with their research. The urgency of imposing rules, specifically on those firms, derived from the fact that there were no specific rules as to the production of research and the…

Identifying orders as retail orders (sometimes referred to as "dumb orders") potentially allows counterparties to bid more aggressively to trade with these orders. That is, it gives retail investors a better price because it increases confidence that retail customers are neither (i) trading on superior information nor (ii) sending a flood of orders on the same side of the market that may move market price in a non-random manner.