Kudos to Commissioner Giancarlo for prioritizing commercial realities. When Dodd-Frank first was adopted, certain U.S. regulators asserted that the rest of the world would follow their example whether or not the rules made any sense. That assertion has proved to be incorrect. In many cases, the Europeans have gone their own way (sometimes adopting more sensible rules, sometimes adopting rules that seem even less sensible), but they have not adhered to the strictures of U.S. regulators.…

A more valuable statistic for regulators to report might be how many "voluntary" whistleblowers attempted to raise red flags internally before going to the government. An announcement bragging about rewarding employees who may or may not make an effort to resolve problems internally first could send the wrong message and may create the wrong incentives. Isn't it possible that bestowing money on employees who refrain from addressing problems within their firms encourages them to remain…

Despite being the SEC investor protection advocate, Mr. Fleming seems to be promoting legislation that would incentivize lending to municipalities instead of private enterprises. His argument requires some consideration. Are retail investors served by a campaign for measures that would incentivize lending to municipal entities?

Mr. Fleming's hypothesis is that lending to munis has been effectively discouraged by employers' migration from defined benefit pension…

If ever a rule were designed to fail cost-benefit analysis, the SEC manifesto on conflict minerals is it. When 97% of companies are not sure where the money is going, chances are that the data is useless.