The new Priorities Letter offers a lot to talk about, since FINRA has managed to cover virtually every aspect of a firm's business. It is incumbent on each firm to go through the letter carefully and scrutinize every relevant priority. The following areas might be of particular interest: (i) custody, (ii) seniors, (iii) improving the automation of "suitability" reviews (e.g., the ability to search for concentrated positions, or positions with excessive turnover), and (iv) cybersecurity…

Mr. Clayton appears to have significant experience in matters of corporate law. Nominating an attorney with real business experience (as opposed to a litigator) to lead the SEC is a change in approach. Enforcement always must be a priority for the SEC, but it need not be the primary concern. A significant part of the SEC's mission concerns the development of a regulatory system that fosters economic growth.

There are two vacancies on the Commission: one Republican and one Democrat (…

The consensus among both buy- and sell-side market participants is that there has been a decline in liquidity. One would expect liquidity to decline as a result of the Volcker Rule for a number of reasons. For one thing, it is difficult for a bank to demonstrate to regulators that its trading activities are permissible market-making and not impermissible proprietary trading. As a result, banking organizations are likelier to withdraw from the market than to risk regulatory repercussions. It…

There is not much in this report to get excited about. That the regulators are cooperating with respect to rulemaking is generally a good thing, but it does not necessarily say anything about the quality of the rules being adopted. The numbers demonstrating that banks have become more "resilient" are so high-level that they are of no particular value.