Commissioner Berkovitz makes the case for supporting futures contracts on sporting events, while distinguishing the ErisX proposal to list futures on NFL games. It is difficult to see why limiting the availability of the NFL futures contracts to sophisticated investors would be an antitrust violation. Many financial contracts are available only to limited types of investors. Certainly, the securities exchanges commonly recommend to broker-dealers that certain listed contracts with a…

This enforcement action is light on the details, making it impossible to judge whether the firm was engaged in egregious misconduct or the transaction sizes were so small that commissions were more akin to ticket charges. If 236 transactions produced only ,083 in excess commissions, then that is only about 0 a trade. Were the transactions very small? Were the customers sophisticated? Were the securities hard to obtain and did the firm have to go to extra lengths to obtain them? What kind of…

While payment for order flow is a legitimate area for discussion, the more significant issue is why customers don't use full-service brokers that provide them with some level of guidance. Congress and the SEC should consider whether over-regulation and the threat of enforcement actions are killing the business of full-service brokerage, leaving retail customers essentially on their own.

Unfortunately, asking the question as to whether regulation may be excessive or have unintended…

According to the Acting Chair of the OCC, "[Climate] risks can arise in many ways including contexts that relate to climate change, either because of physical conditions or climate-related transitions in business and other environments." He then goes on to say that the OCC is going to meetings and "cataloging" the risks.

Given the importance that the regulators are attaching to the issue of climate change, it is incumbent upon them to be more transparent as to the specific risks that…