This study contains interesting information and Senator Warren should be commended for making substantive arguments in support of the DOL's proposed fiduciary rule.

The Senator should release the underlying data of her report to the public to provide added support for her arguments and to allow academics and other interested parties to review her conclusions. One flaw in the report, at least in terms of entering into a genuine discussion of the issues, is that it is intended to be…

Big firms should find that they are already in compliance, other than the necessity of revising their official compliance manuals to incorporate the NFA's express requirements. Small firms, however, are likely to struggle with many of the suggestions that are (bullet-pointed) in Notice I-15-23. This new set of requirements provides a counterweight to SEC Commissioner Aguilar's concerns as to the difficulties that small businesses face in avoiding becoming victims of cybercrimes. On…

According to Secretary Perez, the DOL's proposed rule is nothing more than "common sense." But rules that are based on mere common sense do not take hundreds of pages to explain, nor do they cost hundreds of millions of dollars to implement. Still, the fact of the rule's complexity does not mean that it is inherently flawed, even if there is a great deal of opinion to that effect. It does mean that a meaningful defense of the law should be based on real economic analysis.

Secretary…

Mr. Donohue's advice to CCOs was not comforting. CCOs must hope that Mr. Donohue's list of their duties was intended to be aspirational because the tasks he described were daunting: knowing and keeping up with potentially multiple bodies of fast-changing laws in many jurisdictions, having a complete understanding of firms' businesses and products, mastering firms' technologies, and being a determinative force in establishing their culture - all this in addition to expecting CCOs to implement…