Several of the financial management areas of focus are as to issues where there is not actually a rule in place; e.g., liquidity management and transition from LIBOR. That does not make them any less significant. Firms may want to consider how they institute operational procedures to deal with regulatory expectations where there is not a specific rule that drives the firm's conduct.

As NYDFS launches this new initiative to protect consumers, New York officials might want to consider additional ways to improve the business climate in the state. A quick web search turns up (i) a in terms of its policy environment for small businesses. which ranks New York much higher (28th) for business overall only ranks it 37th for regulatory environment. While New York has numerous historical advantages in maintaining its standing as a desirable place to live, the world changes: and…

ESG is a broad and open-ended concept which provokes many questions that do not have clear answers. Whose decision is it as to what is "socially" correct? What is the relationship between the manner in which a firm is governed and sustainable finance? Are startups that provide their founders with disproportionate governance influence inherently inconsistent with "sustainable finance?"

As a practical concern, the statement that ESG disclosure is inherently "material" seems an…

Based on the public press release and comments, this proposal seems to unduly elevate procedural issues over substantive ones. (Note the proposal is not yet available on the SEC's website.)

Having one market system plan rather than three is not going to change the reality that the exchanges and the broker-dealers have interests that are fundamentally adverse to one another: each wants to "own" as much data (intellectual property) as possible, give away as little data as possible, and…