Firms should consider reviewing this SEC Bulletin with their retail sales personnel. For firms that discover that their retail sales personnel are selling classes of shares that might not be appropriate, more training may be necessary regarding client suitability profiles.

Given the CFPB's political orientation, there was never any doubt about the outcome of the study.  See also the testimony of Professor Adam Levitin, who defended the CFPB's work by calling it "mission-driven" (even though many would prefer that government employees' work be truth-driven). Given CFPB's history of biased research, it would be foolish to accord much weight to this study. See, e.g.,  (House Financial Services Committee…

The Joint Member Agencies' statement makes no mention of two significant issues in the government securities markets. First, only one major clearing bank for government securities is expected to exist in the near future. Second, the new leverage limitations are reported to damage the repo market in government securities significantly. These negative developments are probably the result of new regulations.

The disappointing thing about the Joint Member Agencies' statement is not the…

The recommendations offer a lot to consider about the ways that markets function and investor disclosure works. Trading firms should review the various statements carefully regarding the proposed procedures for stopping and restarting trading generally and in individual stocks. The customer disclosure issues might not be controversial in substance, but firms should consider whether the requirements concerning those issues will be difficult operationally.

As a matter of regulatory…