Chair Gensler raises important questions on market structure. Markets and market technology have changed since the adoption of Regulation NMS. Improvements require periodic and substantial revisits.

That said, pushing for T+0 settlement seems to be evidence of an overwillingness to force changes that may be detrimental in practice. The rate and amount of change simply may be more than businesses can bear. The impetus to move to T+1 settlement was arguably an overreaction to issues…

The FINRA proposals are significant not only as to the volume of information required to be reported, but also as to the technology that will be required to deliver this information to FINRA and for FINRA to sift through and organize it. While there is no doubt that certain of this information will benefit the regulators in better understanding the market, firms should consider what the costs will be of providing the information, and whether there is a subset of the information that would…

The SEC's action dismissing Chair Duhnke and Chair Gensler's intention to replace the entire PCAOB board are notable in at least three respects.

First, and as a practical matter, the SEC's change in PCAOB leadership will most likely result in a significant increase in enforcement actions against accounting firms and individual accountants. That accountants may be targeted more aggressively in enforcement actions will certainly have an impact on the relationship between accountants and…

While it is clear that the CFTC Commissioners are enthusiastic about playing a role in climate change, that role should be limited. In the case of carbon markets that are regulated by the CFTC, the CFTC has an obligation to understand how price discovery in those markets works so that it can regulate trading and be on the lookout for improper trading activities. It is not apparent why the CFTC would deem it necessary to mandate "climate risk disclosure" by CFTC registrants. The CFTC should…