There are a number of interesting observations and recommendations contained in the report, including that certain of the post-Dodd-Frank "reforms" created "dysfunction," by discouraging "bank-affiliated dealers from allocating capital to relatively low-risk activities like market making [in Treasury securities]."

Given that the G-30 is largely a bank-regulatory-centric group, the report seems to suggest providing the bank regulators with greater authority over securities markets…

Firms should also be for outsourced tasks, and that such tasks must be supervised as if they were conducted in house.

As the securities business becomes more dependent on complex technology, firms become more dependent on outsourced providers. The securities regulators take the view that firms are fully as responsible for the work of outsourced providers as firms are for work performed in house. This means that firms must consider, as to each of their outsourced providers, how they can supervise the relevant activity and what they can do if something goes wrong at the provider.

As to prior rule amendments, there is a regulatory process for repeal. It would seem better to follow that process. As with , no one really has an incentive to challenge the whistleblower policy statement in court. In this instance, accused parties that settle a case are not informed of the identity of a whistleblower, and whistleblowers are to be paid more.