As to broker-dealers, it is notable that the SEC just issued a concept release on custody of digital assets by broker-dealers that reflected the SEC's discomfort with broker-dealers custodying digital assets at all. See This statement raises the question of what broker-dealer custodial arrangements of digital assets are permissible.

The revocation of the three existing Executive Orders further serves to: (i) remove a constraint on the authority of permanent agency staff; (ii) remove a constraint on the bringing of enforcement actions; and (iii) revoke an order that emphasized regulatory efficiency.

Risks presented by the entire CAT enterprise are significant. Does it really make sense to gather this much financial information under one roof, given the likelihood that hackers from foreign governments and criminal groups will be targeting the system for that information?

The risks of moving forward are compounded if the entity that is holding the information (and responsible for its protection) is insulated from financial loss in the event of a cyber event.

Two obvious…

While Chair Lee's remarks on the topic were quite short, it would not be surprising if they presaged very significant changes in SEC guidance on climate disclosures. One question to watch is whether the SEC will proceed in this area solely through guidance or whether it will attempt rulemaking.