Pushing for more standardized ESG disclosure by SEC-registered issuers and, assuming there is a changing of the guard at the SEC, may become a focus of the majority of the SEC commissioners. It is one thing to push for the concept of more structured data as to ESG and a harder task to define the data that can and should be structured. What ESG data can be put into a structured form remains very much an open question.

In advocating for greater ESG disclosure, Commissioner Lee is also…

FINRA stated that it has substantial empirical evidence to demonstrate that an employee who has been the subject of a negative conduct finding in the past is much more likely than an employee with a clean record to be subject of such a finding in the future. This accords with common sense as well.

In spite of the apparent benefits of the proposed rule, it is reasonable to question whether the rule may be unduly arbitrary. For example, brokerage employees are tainted for having worked…

There have now been a number of studies of, or reactions to, the mini-financial crisis caused by the pandemic. See, e.g., the ; the statement of "; and the . BlackRock has also , including one on .

Some common threads run through all of these studies: they all find that the financial markets performed better during the pandemic crisis than during the earlier financial crisis, and they all attribute this in good part to some of the changes in financial regulation made as a result of…

Chair Clayton points out in his remarks that raising money for small businesses is not big business. The costs and registration requirements can be onerous.

It is not obvious that deregistration, rather than registration-lite, is the best answer, but it would seem to provide more potential for helping small businesses than the current regime. The real outcome of deregistration at the federal level would likely be to kick the decision to require registration down to the state level.…