The reason that no claims are made against research on ETFs is that no one publishes such research. The reason no one publishes this research is because, under current law, the research might be deemed a prospectus. The reason this statutory amendment makes sense is that current law discourages the production of research that would be very useful to investors. It makes no sense to implicitly bar the production of research on one of the largest and most important investment tools in the…

That the SEC went ahead with approving this product may reflect a shift in policy from the SEC acting as a gatekeeper shutting out new products that it might deem inappropriately risky, to determining that investors should decide the products in which they invest, subject to appropriate disclosures. The latter policy is consistent with the historical mission of the SEC, which is to allow investors to make investment decisions, subject to appropriate disclosure. Of course, this also ups the…

What is interesting about this publication is that it would seem to have no readership. There are virtually no new banks. See Federal Reserve Bank of Richmond, ""; see also George Sutton, "" (American Banker). Thus, the really significant question is not how does one start a new bank, but, rather, why does no one want to do so?

CFTC Chair J. Christopher Giancarlo is a critic of certain aspects of Regulation AT, . It seems unlikely that the Regulation will go effective as currently proposed.