The freeze on the SEC's proxy rules makes some sense from a political perspective; i.e., Rep. Waters wants to maintain the ability of holders of a small number of shares (which is not the same as a "retail investor") to create proxy fights.

However, I still do not understand the reasoning for , unless Rep. Waters thinks that it will encourage the states to go their own way on securities regulation and create a further disruption and breakdown in the (generally) unitary system of…

Notably, the SEC, in adopting , did not impose IM requirements on transactions with affiliates. While the SEC action has only limited impact given the SEC's limited jurisdiction (the security-based swaps market is very small relative to the swaps market, and of even less consequence to commercial companies), the SEC's action is nonetheless consistent with the content of this letter, and implicitly acknowledges that the imposition of margin requirements has costs as well as benefits.

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There are numerous ways in which the arbitrary separation of financial products into those that are SEC-regulated and those that are CFTC-regulated is economically wasteful. To take a simple example, a long position in a basket of S&P stocks and a short position in a futures contract relating to those stocks are hedged, and the margin required of the position should be lowered to reflect the hedge. Instead, because they are subject to two different regulatory schemes, each is margined…

This act by the House sends a very loud message. The contents of the message are, however, not clear.