Commissioner Roisman, as well as Commissioner Peirce in a , make the point that the SEC is going off-track in using the GameStop events as a justification for rethinking market structure or payment for order flow. (Those issues are certainly worthy of consideration, but for reasons having nothing do with the GameStop events.)

What was truly extraordinary about the GameStop events were the decisions made by thousands of retail investors and the communications among the retail investors…

FINRA Rule 2081 expressly prohibits a broker-dealer from entering into a settlement agreement of the type that is the subject of this enforcement action. The broker-dealer was charged with violating that rule and agreed to a disciplinary action for such violation.

What purpose does the additional charge under Rule 2010 ("Standards of Commercial Honor and Principles of Trade") serve? FINRA has developed the practice of adding on a Rule 2010 violation to almost every single enforcement…

GameStop is a great story that should be made into a movie. The report misses the significant aspects of the story: that one guy sitting in his basement was able to capture the attention of thousands of retail investors who communicated with each other on Reddit, away from the regular structured means of interchange intermediated by regulated entities, and move the markets in a big-time way.

The GameStop story is not about whether the settlement cycle should be shortened. The report…

Enforcement actions involving crypto have picked up.

Beyond the timing, there are a number of noteworthy aspects of the action by NYAG Letitia James. First, the actions in regard to the issuance of the interest rate products follow closely on the very that it was prevented by the SEC from issuing an interest-bearing product that was very similar to others being offered in the market.

Second, the NYAG pointed to its authority under the Martin Act to directly regulate "…