Anyone reading this report might be puzzled over what the United States hopes to accomplish with the conflicts minerals rule disclosure requirements. More than half of all issuers report that they do not have the information necessary to make the disclosures. Of the companies that are able to determine whether the minerals that they use are from conflict zones, 60 percent report that they are using minerals from such zones. This leaves only 20 percent that report that they do not use…

The most notable part of the Commissioner's speech was her criticism of the position taken by banking regulators to impose capital charges on customers' segregated funds that are held by CFTC-regulated entities. Her opinion on this point likely reflects a near-unanimous consensus (leaving aside the opinions of the banking regulators themselves). Commissioner Bowen observes that there is some irony in the banking regulators' assertion of a position that may seem to strengthen the…

As to the assertions of Senator Warren and her colleagues, please note:

 gives the SEC Chair essentially plenary power to direct the activities of SEC staff. There is no distinction in the Statute between the authority of an Acting Chair and a permanent Chair. Therefore, Acting Chair Piwowar has the authority granted to the Chair of the SEC by Section 4B.

Contrary to the Senators' concern that Chair Piwowar acted exclusively on the basis of his visit to Africa, Chair…

The most significant commentary was probably that of Investment Company Institute General Counsel David Blass, particularly given the fact that registered investment companies are likely the primary investment vehicle for individual accounts. His points were as follows: (i) even if one believes that the Volcker Rule provides some benefit, the rulemaking and interpretative process that the Rule requires makes it almost impossible to obtain any regulatory advice or relief, (ii) the Volcker…