When it comes to the ways in which fees are calculated, it behooves CTAs and CPOs to check the accuracy of their disclosures.

Chair Massad deserves credit for undoing some of the damage that would have been caused by the prior CFTC Chair's overreach. That said, the faster and more aggressively that Chair Massad can pursue the so-called "fine-tuning" of past mistakes, the better it will be for the economy. On a less positive note, the problems with central clearing are not easily correctable, and the solution will require far more significant action than simply shoring up individual clearinghouses in the event of…

More of this kind of back-and-forth exchange between the industry and industry observers (expressing views that are both positive and negative) is needed. The authors of the Report should take the SIFMA response as an opportunity to defend their work or add to it. The broad conclusions of the Report should encourage others to comment as well. An important goal is to avoid a situation in which open discussion disappears in the .

Notwithstanding the…

This is a thorough and practical report. Although it focuses on providing e-advisory services to customers, much of the discussion is equally relevant to firms that provide personalized advice to customers (e.g., the section that pertains to asking customers about their objectives and potential risks: different results can arise from identical situations). This report should be reviewed by anyone (broker-dealer or adviser) who is responsible for providing advice to customers – or for…