Given that out-of-the-country bad guys are unlikely to be much deterred by this penalty, and that cyber-protections of news agencies are outside of the corporate issuers' control, issuers should take this enforcement action as a precaution to consider the timing of their distribution of press releases. There seems to be no assurance that such releases can be kept protected until their official distribution time.

A comment published in 2013 in the Guide to Hedge Fund Regulation captured the prevailing view of Form PF at that time.

[M]any of the questions in Form PF are horrendously written with the result that it is not entirely clear that the Form is even getting at useful information. Even if the information might be useful, funds will inevitably answer the questions in quite different ways, making the information far less useful than it might have been if the Form were better…

A separate rule set for CABs is a good idea. The current system of broker-dealer registration and regulation is simply too much for firms that are engaged in limited kinds of securities activities. As a result, firms either must give up on registering, forgo the broker-dealer business, or get hit with excessive regulatory costs. Providing an appropriately tailored form of regulation should boost compliance significantly. When it comes to the details, firms should comment on what works and…

, "The four mainstays of the [Vanuatu] economy are agriculture, tourism, offshore financial services, and " [emphasis supplied].