Even if their conclusions proved valuable, it is not obvious how accountants would make determinations regarding the sustainability of intellectual property, how they would develop the expertise to do so in an objective fashion, or who would pay them to make such determinations.

Firms engaged in Regulation A+ offerings should review their compliance procedures promptly to ensure consistency with FINRA requirements.  

This case does not address fundamental questions of whether the aggrieved investors had (i) the right to obtain the information they requested and (ii) a legitimate expectation of receiving an honest answer. Another interesting question is whether the broker would be entitled to an honest answer if the broker had asked a customer, "How much are you willing to pay for these bonds?" The first question is important (whether or not the customers had a right to the information) because it goes to…

The departure of Commissioner Gallagher will be a loss to the financial markets. His practical understanding of how markets work has been invaluable. Most compelling was his  of the burdens that the Dodd Frank regulations imposed on the markets. That presentation provided evidence of the drag that the sheer volume of regulation (to say nothing of its "quality") imposed on the markets and the economy. See SEC Commissioner Gallagher Announces Updated Regulatory Chart (with Lofchie Comment…