Taken on its words, the rule change is non-controversial and is a recitation of existing law. But query whether the rule change in anticipation of the SEC doing away with the Trade-Through Rule? See .

The CFPB's move to regulate EWA as "credit" in the name of protecting borrowers, more likely had the effect of making it more difficult for workers to get access to needed funds.  

An important to-do still in the SEC's court is responding to SIFMA's request for some relief as to the  collateral segregation requirements. As originally approved by the SEC, the Rule 15c3-3 requirements for clearing of US Govs are overly complicated and create a substantial drain on broker-dealer liquidity.  

Given the importance of the US Government securities markets, it is surprising how little consideration seems to have been given to the operational complexity…

In wishing the best for new Chair Selig, it should also be noted that Acting Chair Pham had an impactful tenure in that role. She accomplished a remarkable amount to clean up nonsensical regulations. She made the CFTC's regulations more harmonious and less duplicative with the SEC's regime, curtailed enforcement overreach, and introduced a sensible regime for crypto assets. A job well done.