This rule will be adopted, in one form or another. Accordingly, firms planning to comment should focus on the specifics of the proposal's requirements - most significantly, the information that they would be required to monitor. Firms should also consider whether the triggers for notification to the regulators have been set at an appropriate level.

Here are a few questions to consider: will the imposition of reporting requirements as to liquidity eventually result in the adoption by…

The SEC also recently issued a statement asserting jurisdiction over certain transactions involving blockchain products. (See ) This raises the possibility of a regulatory dispute over jurisdiction. Each agency is perfectly correct in interpreting the relevant statutes to the effect that at least some transactions involving virtual currency or other blockchain products will fall within the ambit of that agency, and perhaps within the ambit of both. What is significant in the regulatory…

Ms. Peirce is a scholar, in addition to having a background at the SEC and as a staff member in Congress. The Cabinet has published a good deal of her work, including her .

Robert Jackson is known for his work on .

Ms. Peirce had been originally nominated for the Commission by President Obama in March of 2016, along with Democrat , a professor at (with Ms. Peirce being the "Republican" nominee and Ms. Fairfax the "Democrat"). However, the two nominations were derailed,…

Firms should consider if there are procedures that can be used to prevent such activity. At a minimum, given the warning that this case provides, firms should consider on what basis decisions as to IPO allocations are made.