Commissioner Roisman's remarks on mandating ESG disclosures by investment advisers are a perfect example of the concept of "turnabout is fair play." See . That is, advisers who want more information from the issuers in which they may potentially invest are also subject to the obligation themselves to provide more information as to the manner in which they make investment decisions.

This is not in the least to criticize the concept that advisers may market themselves as investing in a…

ESG is an amorphous term. It can include everything from climate change to employee satisfaction to the conduct of whistleblower programs to information security programs, and numerous other related and unrelated issues. For GAO's study to be meaningful, it should have asked investors what specific topics they wanted information on, why they wanted that specific information, and how they currently use information of that sort in making decisions. Ideally, GAO might also ask how much…

As acronyms go, this is pretty good. Honors in that regard still go, and it's not close, to the .

These are both sensible interpretations. The margin requirements are generally intended to protect broker-dealers from making overly risky loans where they cannot really liquidate the collateral. Therefore, it makes perfect sense that broker-dealers would not have to collect additional margin where they are able immediately to sell securities provided as collateral even where the customer might have been limited in its ability to sell.

The second interpretation really is not…