This rule is going nowhere. Whatever the legal theory for purposes of Administrative Law, the OCC is not going to advance it over the objections of the President.

As a practical matter, billionaires tend to have choices, including as to where to live. Before the pandemic, New York City was a fairly attractive place to live. Right now it is less so. New York State currently has a maximum tax rate of 8.82%. This bill would effectively substantially raise and accelerate the New York State tax rate imposed on the very rich . (New York City also imposes income taxes.) By contrast, Florida does not have a State income tax. See .

How many of those 113…

One of the most important issues that the financial regulators (not just the SEC, but the CFTC and the banking regulators, as well) should be considering is market liquidity. Money market funds should be only part of the focus; clearinghouse margin requirements are another important piece of the puzzle.

It will be interesting to see how much attention the SEC and the regulators will devote to these crucially important, but somewhat esoteric, issues as opposed to issues that may be…

According to the numbers cited in the letter, New York State's share of the financial services business dropped by over 25% in a six-year period. After that drop, the country was hit by a pandemic that (i) made New York City a far less attractive place to work (no restaurants, no theater) and (ii) made it clear that it was not necessary for many jobs to be performed in New York City (remote working). In light of those somewhat discouraging facts, the officials of New York State might wonder…