In statements that might have sounded familiar to Goldilocks, the three SEC commissioners voiced three different views on the final rules: Commissioner Stein said that they do too little, but are better than nothing, Commissioner Piwowar complained that they comprise a part of an ill-conceived scheme of regulation that exacerbates the problem of too-big-to-fail, while Chair Mary Jo White declared that the rules are just right.

Commissioner Bowen's warning that a single country's regulators should not go it alone is true. The comment might best be directed at her own agency, the CFTC. There is no other regulator whose conduct has made it such an obvious target of her warning.

This enforcement action reminds broker-dealers to continually review the effectiveness of their current compliance checks and exception reports. In particular, it is incumbent upon the firm to take the time necessary to review internal control procedures to determine whether an order should have been stopped before it hit the market.