Chair Clayton's view that the SEC should discourage short-term investment is debatable. The more liquid the equities markets are, the more attractive they are; discouraging short-term investment is clearly antithetical to liquidity. By contrast, the remaining issues enumerated by Mr. Clayton are clearly at the heart of the SEC's reasons for being, as set out in the securities laws.

The SEC has a tough challenge in ensuring that local governments provide good financial information.  The SEC cannot find it attractive to bring governments or government officials into court.  On the other hand, it should not be left entirely to broker-dealers to police issuer disclosure. 

Even more than investment bankers, IT professionals in a firm may have access to inside information - and if they do, it is very likely about numerous companies. Accordingly, financial institutions should give consideration to limiting that access, bearing in mind that it may be a difficult task. 

The regulators' joint statement may reflect an acknowledgment of the enormous expenses to which financial institutions have been put in complying with AML obligations and the fines that have been imposed for even unwitting failures to fulfill those obligations.