As he has , Mr. Dudley has been consistent in expressing this view of regulatory developments. Suffice to say that others have expressed different views on many of these regulatory developments. For example, some have argued quite convincingly that the move to central clearing creates as many risks as it resolves (and that the new risks are more serious). See, e.g., ; see also .

With a change in administration comes an opportunity to reexamine the statute and financial regulation generally. Dodd-Frank is an ill-conceived statute that confuses quantities of regulation for quality. It is unfortunate, but understandable, that the outgoing regulators who implemented the statute continue to support it rather than address its deficiencies.

This proposal is meant to serve political and not regulatory purposes. If energy prices spike (as they often do in the ordinary course), proponents of the proposal will assert that the rule would have kept prices down if it had been adopted. Beyond that specific use, the proposal will be ignored (and rightly so).

Numerous firms have received FINRA inquiries regarding connections they might have with the sale of microcap securities. All firms would be well advised to revisit the quality and adequacy of their compliance procedures in that area.