Reductions in the charges associated with securities financing transactions and cleared derivatives would be overdue good news to the securities and financial instruments markets.

It is difficult to see any consistent theme as to when the DOJ becomes involved in violations committed by regulated entities. On the one hand, DOJ brings criminal cases against traders for spoofing activity. The improper activity in such cases often falls in a gray area where it is not always obvious which types of trading are permissible and which are not. See, e.g., . On the other hand, this case reflects what is, essentially, an outright theft. There seems to be no real ambiguity about…

Interesting that Ms. Peirce and Mr. Roisman - who conceded to the adoption of Regulation Best Interest (perhaps as an attempt at compromise) - now object to the addition of further rules that are effectively supplementary to Regulation Best Interest. Having crossed the line in redefining the role of the SEC from a disclosure regulator to a suitability regulator, Ms. Peirce and Mr. Roisman may find it difficult to justify any particular stopping point in a broker-dealer's suitability…

While regulators may say that enforcement statistics don't matter, they obviously do, since every regulator touts its enforcement statistics. If they don't matter, why talk about them? If they do matter, what about them does? Do higher numbers reflect better enforcement? Or more aggressive enforcement? Current enforcement or past efforts? (These questions are appropriate to ask of (almost?) every agency that has an enforcement division.)