Given the absence of any specific requirements as to how the compensation calculation should be made and the complete absence of any reasonable policy rationale for this rule (after all, the CEO's salary is disclosed), issuers have significant flexibility as to how to comply with this rule. Don't waste resources overthinking the reporting methodology. The important compliance rules are (i) choose a methodology (doesn't really matter what it is), (ii) fully document it,…

That one of the most significant entities in the clearing business is pulling back demonstrates how ill-conceived the rush to force central clearing was, and how much of it simply did not live up to the hype. Central clearing is a viable procedure for the most liquid derivative products; it is not a replacement for a diverse OTC market.

New SEC Chair Clayton has pledged to focus on improving the ability of companies to raise money in the public markets at a reasonable cost. This is an important change to the persistent governmental mindset of "ever more regulation." After almost a decade of regulatory explosion that has shaped the norms and expectations of government behavior, any real reduction in regulation seems extraordinary.

One aspect of the recommendations was odd: the notion that it is not clear who must…

The number of firms that have been sanctioned for improper sales of mutual fund shares is very high. Clearly, this is an area of focus for regulators. They are looking to find instances where retail customers are being disadvantaged. Even firms that are not completely confident in their compliance procedures, particularly technology procedures, should make sure that they are working with this in mind.