When technology is not working, that failure creates the capacity for a remarkable number of violations; e.g., in this instance, 147,000 violations due to the technology failure vs. 167 errors due to the manual process failure. Of course, the technology is indispensable, but the numeric difference in the number of failures really illustrates the importance of having compliance procedures that review the end results of technology processes.

The Democratic Commissioners have regularly dissented from SEC rule makings that would reduce disclosure burdens on SEC-registered issuers. In fact, as here, they have regularly argued for increased disclosures, particularly as to environmental, social and corporate governance factors. That may be a sign of things to come. See, e.g., .

One of the most interesting statistics in the IAA report is the steady rise in the number of investment advisers (up from about 11,000 in 2014 to about 14,000 in 2020) compared to the steady decline in the number of broker-dealers (down from about 4,000 to about 3,500 in the same time period). (See Page 38 of the report.)

Doubtless there are many causes for the decline in the number of broker-dealers, but regulation has to take some share of the responsibility for the decline. There…

Director Hinman's advocacy for principles-based disclosure by issuers is consistent with the current majority view of the SEC Commissioners. (See, e.g., the stated positions of the Commissioners Clayton, Roisman and Peirce with the notable exception of Commissioner Lee. . See also .)

Director Hinman . Assuming that the Democratic commissioners become a majority at the SEC, there may be a meaningful reversal of priorities, particularly in the Division of Corporate Finance, where it is…