This enforcement action again demonstrates that the number of violations that occur when there is a technology failure relating to trade reporting is astronomical. This means that FINRA's guidance as to the appropriate level of fines is meaningless, since, under the guidelines, even the largest firms could be hit with fine amounts that would be devastating.

One of the industry's most significant requests to Congress is that the government should acknowledge that the government is itself a material potential source of vulnerability in data protection. Put bluntly, information that is collected and stored by the government may be more accessible to hackers than the information stored by private parties. Given the vast quantity of information that may be collected by the government, a raid on the government's information could be a far larger haul…

A Cadwalader memorandum on the SEC's proposed Regulation Best Interest was titled "." A major point (or argument) of the memorandum is that it is not possible to have both. To paraphrase, if a broker-dealer can not make any recommendation to a client without taking on a fiduciary obligation to that client, then the economics of being a full service broker-dealer (providing recommendations but just get paid for executing trades) just doesn't seem to work.

When NASAA declares that…

There would seem to be a number of significant differences between the positions of current CFTC Chair Giancarlo and Dr. Tarbert, most notably with respect to Regulation AT. See also