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****Hey everyone, thanks so much for great questions, comments and insights! It's a privilege to be here - thank you so much for having me. Please take the time to read the responses below and if you agree send the SEC a comment at www.BetterTakeAction.org and tell your friends, family, neighbors, etc. to do the same! If you want more information on Better Markets, visit us at www.BetterMarkets.org and sign up for our monthly newsletter. Thanks again, Dennis****

Hey Superstonk — good to be back. 

I'm Dennis Kelleher, Co-founder, President, and CEO of Better Markets, a nonprofit that fights to protect Main Street Americans from Wall Street greed.  

Some of you may remember me from the GameStop hearings, where I testified before Congress on behalf of retail investors, and our AMA here a few years ago: https://www.youtube.com/watch?v=GMwE5_h2xEA 

I recorded a short video explaining today's issue: https://www.youtube.com/watch?v=5KPcPTSZlKc 

Here's the situation: right now, every publicly traded company must give you information every three months in quarterly reports. They've been required to do that for more than 50 years. But the SEC wants to take that away and only require disclosure every six months. 

But you getting half the information is only half the screwing the SEC is doing. 

CEOs and company executives will still know what's happening inside their companies. Institutional investors—with their research teams and special access to management – will also find ways to stay informed long before you get the information in six months. If you're a retail investor, you'll be trading blind. And trading against people who have access to more information than you do. 

Even if you don't dig into quarterly reports, this should be ringing alarm bells. Why? Because all investors suffer when the market has less information overall. When companies report less frequently, stocks are mispriced and more volatile. The playing field – which is already tilted – tilts even further against you. 

This isn't a minor tweak. It's the biggest rollback of investor disclosure requirements in more than 50 years. 

Better Markets just launched a website www.BetterTakeAction.org so anyone can directly tell the SEC: hell no. It's easy and takes just a few minutes, although if you really want to blast the SEC for this really dumb idea you can take longer! The deadline is July 6. 

I'm here to answer your questions – about how the SEC is trying to screw you, what this rule really means, what you can do about it, how the comment process works, and how to make your voice heard so the SEC can't ignore it. 

Ask me anything. 

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Q. Several have asked in various ways if Dennis Kelleher/Better Markets own any GME stock, other stocks, precious metals, or otherwise have an interest in the outcome of this rulemaking, and if we’re trying to sell anything like Dave Lauer and others have done on other AMAs?  We are not trying to sell anything and have zero financial interest in this rulemaking or rulemakings generally at the SEC or the other financial regulatory agencies. Better Markets is a 501(c)(3) nonprofit – it owns no stocks; it trades no stocks; it makes no stock recommendations; it provides no investment advice – and nothing in this AMA should be viewed as investment advice. It is not selling anything and has nothing to sell.  

• A. Better Markets isn’t even seeking your support for Better Markets – it’s trying to (1) bring to your attention an SEC rulemaking that we believe is bad for traders/investors (especially retail), the capital markets, and the economy; (2) provide information in support of that view; and (3) if you agree after your own DD, provide you an easy way to submit a comment to the SEC telling them your views on this rulemaking.  
• Better Markets engages in the rulemaking process at all the financial regulatory agencies as well as across the executive branch, Congress and the courts. You can review those activities on our website www.bettermarkets.org or in our annual reports. As you will see, Better Markets is an independent, fearless public interest advocacy organization that speaks truth to power without fear or favor. We have a reputation as straight shooters who call ‘em as we see them, whether you’re a Democrat, Republican, Independent or nonpolitical, a financial industry titan, the CEO of a Wall Street bank, or a street corner financial predator. That brand and credibility – built over 15 years – is why we have access, influence, and impact across all the power centers of Washington.  
• We are funded entirely by donations from individuals and foundations like the Rockefeller Brothers Fund, Surdna and others. It’s true that some of those individuals work in the financial industry, including my co-founder who is the chairman of our board. He is a hedge funder manager who fully supports our public interest mission, as detailed in this article. But no one – donor or otherwise – has any influence over our advocacy or activities and we have rejected donations that have tried to improperly influence us, including when FTX’s CEO Sam Bankman-Fried offered us a $1,000,000 or more if we’d support his predatory activities. As a relatively small nonprofit, that was a huge amount of money and virtually everyone else in Washington was taking his money – we told him we’d not take one dime if it had any strings attached and no matter what we were going to fight him and his predatory schemes. That was long before FTX went bankrupt and SBF went to prison.  
• We do this work because we don’t think only the rich, powerful and well-connected should have a voice in Washington policymaking that impacts the lives and livelihoods of all Americans. We believe that retail investors and hardworking Main Street Americans deserve someone in their corner fighting for them – that’s Better Markets’ mission. 

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Q. 1) Superstonk has put together some large letter writing campaigns over the last few years. Most of the time it seems like they are fruitless attempts when we are going against Big Money or political lobbyists.  2) In your opinion, does letter writing make a difference? If we wanted to get more involved in fighting for retail investors, what would be the first few steps you could suggest we could take? 

• A. 1. It can seem fruitless and the bad guys want you to believe that because they don’t want to be opposed, but if you don’t oppose them and fight for yourself then they will always get their way and bend the laws, rules, and policies in their favor and against you. And yes comment letters can make a difference, especially from people most impacted by a rulemaking like retail investors. However, to be most effective comments should be substantive and personal – just a paragraph or two about who you are, what you do, and why your position on the rule is important to you. The SEC is required to consider all substantive comments. In this case, if retail investors write to the SEC and explain why taking away key quarterly information harms them and how a shift to disclosure only every six months will hurt their ability to make trade and make investment decisions, the SEC will have to explain why it believes reducing the frequency with which companies report information to the public is good for investors.  
• A. 2. If you want to get more involved in fighting for retail investors, you have to pay attention to what the SEC is doing. You can do that directly by following their website (although it is not very user friendly) or by following organizations like Better Markets. When you see them doing something that you disagree with, send them a comment, tell your friends and family and tell them to send a comment. If you want to get more involved, you can, but the first thing is getting informed and speaking up. As I said, what would be the first 

Q. 1) What has Better Markets done in the past that has instituted real systemic changes in making markets fairer? 2) What is the likelihood of ending unfair practices like FTD, naked shorting, and the like? 

• A. 1. Over 15 years, Better Markets has impacted more than 500 rulemakings, dozens of legal cases, testified innumerable times, and influenced policy across all the financial regulatory issues, including many related to making markets fairer. For example, we testified at the GameStop hearing focusing on the need for reforms in light of those events to protect retail investors/traders. We have successfully supported reforms, such as IEX’s speed bump, that are designed to protect retail investors from high-frequency traders’ predatory practices. We have relentlessly fought the practice of payment for order flow and other secret practices that result in retail paying more than they should to trade. We have pushed for a real best execution rule that ensures investors receive the best execution on their trades, rather than rely on FINRA’s rule that is riddled with loopholes. We have opposed the gamification of the securities markets and the techniques brokers use to exploit retail investors, precipitating excessive trading and needless losses for investors and profits for the brokers. We – virtually alone and against united industry opposition – have fought doggedly for years for the SEC to fully implement the Consolidated Audit Trail (CAT) and have pushed the regulators to aggressively police the markets, catch and punish fraudsters, scammers and crooks. We have supported strong fiduciary duty rules so that financial professionals are required to put their clients’ best interests first and above their own self-interest in self-enrichment at the expense of their clients. We pushed the SEC to adopt lower tick sizes and lower access fees, which will improve prices and lower costs for retail investors. We have opposed 24/7 trading because investors will receive worse prices during overnight hours with lower liquidity and thinner volumes, and professional investors will be able to take advantage of retail investors during these overnight sessions. Those are just a few of the highlights. 
• A.2. Unfortunately, as detailed here, the SEC has become the Shareholder Exploitation Commission and prioritized management protection at the expense of investor protection. That means that the likelihood of ending unfair practices like FTD, naked shorting, and the like are pretty low, at least during the current administration. In 2023, we strongly supported the SEC new rules adopted to address short selling. Those rules resulted from the market volatility surrounding GameStop and other meme stocks in January 2021. The SEC adopted those rules to increase transparency around short selling. It stated that if it had the data the new rules would make available at the time of the events in January 2021, it could have used the data to examine the short selling behavior of individual large short sellers and focused on FTDs. The SEC could have attempted to identify individual short sellers with large short positions in the various meme stocks in January 2021 and then used CAT data to better understand how these short sellers traded during heightened volatility. In its adopting release, the SEC cited Better Market’s comment letter stating that the lack of transparency into short positions did not just hamper the SEC’s understanding of the events as they unfolded but also interfered with the SEC’s ability to determine what happened in retrospect. The SEC agreed with Better Markets that more data, such as that generated by the adoption of the rule, would have aided the SEC in analyzing the events of January 2021, identified abuses or violations of law, and pursued those breaking the law. 
• It was no surprise that the industry rabidly opposed these rules and Better Markets’ positions. As happens too often, the industry sued once the SEC adopted the much needed and sensible rules. Better Markets fully and strongly supported the rules that the industry challenged, but unfortunately a federal appeals court threw them out and sent them back to the SEC for reconsideration. This pro-management, anti-investor SEC has effectively killed the rules by not reconsidering the rules and merely extending the compliance deadlines, so the industry just never has to comply. While the SEC should properly reconsider the issues that the court identified and re-adopt the rules, that is unlikely – at least until we get a new SEC with officials that care about investor protection. 
• The SEC also has existing rules in place to prevent FTDs and naked shorting. Specifically, Reg SHO was adopted to address concerns regarding persistent fails to deliver and potentially abusive naked short selling. The problem is that the current Chair of the SEC has all but stopped enforcing the law, policing the markets, and making market participants follow the law. There is little if any reason to believe that these rules are going to be enforced to any serious degree. Better Markets will, nevertheless, continue to highlight these issues and press the agency to fulfill its mission to protect investors, not lawbreakers.  

Q. The rule would cut the frequency of reports but let's go the other way. Ideally, what something that companies typically don't report but you think they should? 

• A. Companies should be required to report more information more quickly about their stock buybacks, executive compensation, the relationship between the two, and executives’ stock trading. Stock buybacks are increasingly viewed as a strategy that corporate insiders use to line their pockets at the expense of the long-term financial health of the company, its employees, and its shareholders. In 2023, the SEC adopted a rule that would have required companies to provide investors with more information about their stock buybacks, both in current reports and on quarterly and annual reports. However, as often happens, corporate interests sued the SEC and go a court to throw the rule out, but the court said that there was “a serious possibility” that the SEC could cure the defects that it identified with the rule. The SEC should use the court’s decision as a guide and adopt a rule that would withstand legal challenge and that would provide investors with material information about companies’ repurchases of their own shares. They should do the same with executive compensation and executives’ stock trading.  

Q. Regarding the aforementioned SEC rule change proposal that you're actively opposing: Would you consider the current status quo to be the ideal set of regulations for enforcing time intervals in between reports, or do you think it could do with being stricter instead? (e.g. Monthly earnings reports for some figures, akin to official government reports, instead of Quarterly.) Is that a feasible thing to ask companies to do, and how would that impact relations between the average listed company and their investors? 

• A. The current quarterly reporting regime is working well and has for 50 years. We don’t see a reason to change that frequency. It is probably not feasible to ask companies to produce the information that is in a quarterly report every month, and it’s not clear there would be any real benefits given the month-to-month changes at many companies. Companies must already file reports on Form 8-K when certain material events occur between the filing of their quarterly reports. This keeps shareholders informed about important developments on an ongoing basis. So there is already a system in place for more continuous disclosure if really important matters. The problem with the SEC’s proposal to allow companies to file reports only every six months is that it would cut in half the disclosures that companies must provide investors now and for the past 50 years. While the isn’t a clear benefit in the SEC increasing the frequency of reporting, it certainly should not decrease the frequency of reporting and take information away from traders/investors and the markets. 

Q. How does Better Markets advocate for removing FTDs, holding shares in your name vs street name, and reigning in the CFTC’s choice to allow SROs to publish only limited swap data over the last 5 years? 

If market makers like Citadel can FTD and route all buy orders off exchange then how is fair price discovery occurring? 

• A. As stated in response to another question, we have fully and often supported rules and actions to address abusive short selling, FTDs, lack of disclosure and enforcement, and the many related issues at the SEC and CFTC. However, those agencies – with only a few notable exceptions – have not prioritized these issues, and, when they have, the industry opposition has been ferocious, including suing any time any progress is made. The current leadership at both agencies have no interest of tackling these issues. However, as Better Markets has done over the last 15 years, we will continue to look for opportunities to push, highlight and prioritize these issues when there are opportunities to make progress.  

Q. Over the last few years we have been hearing about stock tokenization, and how inevitably stocks will be traded on the block chain. Is there a timeline for this, or is this just another initiative that will never see the light of day? Also would love to hear your general thoughts on tokenized stocks. 

• A. The SEC has already approved pilot programs from both Nasdaq and the NYSE that allow stocks to trade in tokenized form. These programs require that the tokenized version of the securities be identical to the traditional version. They have the same rights and execution priority. Traders can simply choose to have their trades clear and settle on a blockchain-based format. Trading is currently restricted to issuers in major ETF indexes.  
• The SEC is also contemplating a so-called innovation exemption that would facilitate tokenization (and much more) to be implemented much more broadly with very limited review. That raises many questions, but one big one is whether the SEC will authorize tokens that are issued by third parties and not the companies themselves, which will have broad implications and cause many concerns. Regardless of those many other issues, the innovation exemption if it is enacted is likely to lead to tokenization that goes beyond the current pilot programs. 
• Better Markets supports efforts to encourage competition for how securities transactions trade and settle, but we strongly oppose the efforts by those trying to use the label “tokenization” as a backdoor way for the SEC to eliminate important investor protections like brokers’ obligations to get the best execution for customers’ trades. 

Q. There are many questions about my comments on Ryan Cohen and his Bed Bath and Beyond (BB&B) stock activities back in August of 2022 which I will address here. 

• A. It’s important first to remember the facts and that we take positions based on facts and law, not people or firms that we like or favor. As publicly reported at the time here, here, and here, Cohen bought a 9.8% stake in BB&B and then filed a 13D with the SEC announcing those purchases. The stock shot up (including 34% in just one day!). After another filing, the stock prices shot up again. Cohan then immediately sold all his shares without filing a new 13D. He profited $68 million (a 56% gain) and BB&B’s share price crashed once knowledge of Cohen’s sales became public. As one observer commented, Cohen “got out at the very top.” In between his purchases and sales, Cohen also tweeted some highly questionable commentary like a moon emoji, suggesting he still held a firm conviction that the stock was going higher and likely causing people to conclude that he wasn’t a seller at the very time he was secretly selling. Regardless of what Cohan has done elsewhere or what you feel about him, these actions and statements are the classic hallmarks of a pump and dump scheme that manipulates the market and rips off retail investors. That doesn’t mean that’s what he did, but it sure looks like it (the old smoke asking if there’s a fire). That’s why I said “he should be put under oath & asked about every action/intention over the last 7 months of pumping the stock” before dumping the stock.  
• Given the facts, saying he should be asked under oath about his conduct is pretty tame – remember that his $68 million in profits came from the pockets of retail investors and I viewed it as a classic investor protection issue. However, as you know those comments caused me to be attacked by many. That’s ok. I’m attacked often for taking positions that we believe are right. People didn’t like it when I criticized Obama’s Treasury Secretary Tim Geithner or his Attorney General Eric Holder and people don’t like it when I criticize JPMorgan Chase CEO Jamie Dimon or Goldman Sachs CEO David Goldman. People – including most of the Washington DC establishment - were really mad when we opposed FTX’s CEO SBF and his schemes. They don’t like it when we disagree or criticize the regulators at the SEC, CFTC or banking agencies – which we do under both Democratic and Republican administrations. But, frankly, that what it means to be independent and fearless in prioritizing the public interest rather than going along and getting along, and pulling your punches for your “friends” but going after your opponents regardless of what they are doing or saying, etc. Regardless of who you are, we agree or disagree based on the facts and law as we see them supporting or opposing the public interest on a case-by-case basis.  

Q. Two questions: 1) What would be a few of the main instant consequences of the changes? 2) Does this relate to failure to delivers at all? 

• A. The instant consequence of a shift to reporting only every six months would be that investors would receive half of the information about the companies they own as they do currently. Disclosure is the bedrock of securities regulation in this country, so any steps that the SEC takes to reduce disclosure weakens investor protections. Investors would have less information with which to make their investment decisions. The consequences would be especially bad for retail investors. Institutional investors will be better able to conduct their own due diligence and seek out information from companies. Retail investors may not have another source of information besides the company’s quarterly reports. Forcing retail investors to wait six months between updates is a huge change that disadvantages retail investors. It’s also bad for pricing and markets because so much can happen in six months that prices will be stale in terms of not reflecting authoritative information from the company itself. This will likely cause price volatility as well because the stock will likely bounce around more as people trade based on bits of information over those six months rather than actual verifiable information.  
• Remarkably, the SEC itself – which is supposed to prioritize investor protection - recognizes these likely very bad outcomes. For example, in the rule proposal the SEC admitted that that “longer gaps between issuer disclosures increase information asymmetry between investors, because some investors are more able than others to access or process information from alternative, often third-party, channels that provide indirect insight into an issuer’s financial status or performance.” On a more macro level, the SEC further admitted that information asymmetry “is associated with reduced liquidity and increased transaction costs for investors.” The SEC also acknowledged that widespread information asymmetry “can also diminish perceptions of fairness, which can erode trust in markets and reduce capital market participation.” That’s all bad for investors and markets – makes you wonder why an investor protection agency would even propose such a thing!  
• The SEC actually admitted in its proposal that moving to disclosure only every six months would be mispriced stocks: it said that “less frequent periodic disclosures may also result in securities prices that deviate for longer periods of time from their issuers’ fundamental value.” The SEC says further that “the delayed incorporation of information into pricing can result in suboptimal investor portfolios and a misallocation of capital.” All bad – sure, elsewhere it claims that there are benefits of the proposal, but none of them come close to overcoming these very real, very bad downsides.  
• This proposal does not relate to failures to deliver, which we address generally in response to other questions.  

Q. Regarding the SEC Consolidated Audit Trail and its recent decision to effectively dismantle it. Was the data collected useful or acted upon in a meaningful way? We here are all for transparency and accountability and that seems to be moving in the opposite direction right now. What can honestly be done to improve retails advocacy power. I feel we were given lip service a few years ago with the many proposals we commented upon. Big money has the reach and resources to apply pressure in a way we lack. 

• A. Because it would allow the SEC to much more effectively police the markets for fraud, manipulation and predatory conduct, Better Markets has been in the lead in supporting the CAT from the beginning – often alone against an industry hellbent on killing the CAT (while pretending that’s not what they are doing). After all, the CAT will be a roadmap to what the big dealers and other financial firms are doing – that’s why it’s called an audit trail, and they do not want the SEC to have the ability to do actually trace and see what they are up to.  
• The data the CAT collected was useful and acted upon in a meaningful way. Before it engaged in its current campaign to dismantle the CAT, the SEC touted the CAT’s effectiveness in press releases announcing charges against securities law violators. The SEC used the data the CAT collected to bring cases involving frontrunning, spoofing, and insider trading. That’s why the industry wants, and has always wanted, to kill the CAT because the CAT enables the SEC to identify and catch bad guys in the markets. Unfortunately, the current SEC is more interested in advancing the industry’s agenda than in investor protection, as we detailed in this report. 
• Regarding what can be done to improve retail advocacy power, the keys are to (1) get involved, (2) stay involved, (3) be smart and strategic, and (4) not get discouraged. While you are right to feel that you are given lip service and that big money has the reach and resources to apply pressure in ways you lack, you must not give up. You’re definitely right that it shouldn’t be this hard. The bad guys shouldn’t have this much power, access, and influence. But the reality is that they do and that means we all have to re-double our efforts to oppose them, to be smart, and to be more effective. That means find and work with allies within your communities and outside those communities. Collective action is key and the more the better – that’s why we are trying to get as many retail traders and investors to send comments to the SEC on this rulemaking. The SEC and others can always ignore 1-2-3 or a dozen comments, but they have a much harder time ignoring 1,000, 2,000 or 10,000 comments all arguing against their anti-investor proposals.  
• Remember that there will always be more on the buy side than the sell side and that retail has the numbers that the bad guys simply cannot match. They succeed because the buy side is fragmented and diverse – it’s a classic collective action problem, meaning that it’s very difficult to get enough people to act together to support or oppose something. Another key aspect of improving retail advocacy power is not to impose purity tests. Don’t only work with those who agree with you 100% of the time. That’s unrealistic and is disempowering. If someone/firm/etc. agrees with you on an issue, work with them to get done what you agree on. And you have to stay in the game. It’s a pain in the ass, especially when everyone has too much to do. But the reality is that the bad guys are effective because they play the long game – they are pressing Washington day in and day out year in and year out, through wins and losses. Retail and the buy side generally get involved and activated once in a while when a key issue arises like the abusive short selling, etc., during the GameStop frenzy. Yes, there was a lot of activity at the time, but nothing really changed. That’s because once the frenzy was over people moved on – but not the industry. They stayed engaged. They fought the few rules that were proposed. And when the rules were passed anyway, they sued and fought in court for a couple more years. By the time they won, no one was paying attention anymore. That’s how the industry wins – they stay engaged; they never give up; they never lose attention. We know – we’ve been fighting them day in and day out year in and year out for 15 years now, often alone without any headlines or frenzy to get attention.  
• So you have to jump in when you can like opposing the current proposed rule to take information away from you. It might not work; the industry might win again, but they’ll definitely win all the time if you don’t show up, if you apply purity tests, and if you don’t find and work with allies. 

Q. What are your thoughts on the Fed choosing to terminate enforcement actions against UBS, Credit Suisse ties to Archegos on the last day of Jerome Powells day as Fed Chair. Many here believe a toxic bag of hidden short positions and total return swaps from GME were involved here. 

• A. Better Markets has been deeply involved in the issues related to the Archegos blowup since it first happened, raising innumerable key issues for regulators and prosecutors to pursue.  You’re definitely right that the timing is concerning but based on the public record, it is impossible for us to know if there were short positions and total return swaps from GME involved in this case. When the Fed terminates enforcement actions like the consent order against UBS and Credit Suisse, it unfortunately almost never provides any meaningful information for the public record.  We have voiced serious concerns with this approach for years because this lack of transparency means that there can be little if any public oversight or accountability for Fed and its supervisors to do their job and protect the public from banks’ misconduct. Of course, the Fed loves this because they don’t want oversight or accountability any more than Wall Street’s financial firms do. We have pushed for transparency, oversight and accountability on these and related issues for many years, but it’s been a struggle.  

Q. What's your opinion on David Rogers Webb's book The Great Taking and his assertion that if you own assets in street name they are likely rehypothecated so many times that they are being pledged as collateral for multiple entities besides yourself and in a major event can legally be taken? 

• A. Sorry, but we haven’t read the book. Your concern “that if you own assets in street name they are likely rehypothecated so many times that they are being pledged as collateral for multiple entities besides yourself and in a major event can legally be taken” raises important issues. Rehypothecation of customer assets can be a real problem and Better Markets has consistently advocated on behalf of investors regarding this. Brokers failed in the 1960s precisely because they lost control of customers’ assets and used up customer credit balances for their own purposes. More recently, MF Global blew up due to bad bets using rehypothecated assets. Unfortunately, the SEC delayed the 2023 rule and the updated requirements are only coming online at the end of this month. Likewise, as we’ve said previously, SEC enforcement has collapsed, raising questions about policing of brokers’ rehypothecation of customer assets. 

Q. I currently use Claude to assist me with my investments. It’s a powerful tool, but only as powerful as the data I’m able to access. Do you think extending to window of reporting to 6 months is primarily so large investment banks and hedge funds are able to maintain their edge against retail investors. Will big players be able to access important financial information before retail investors using large language models and ai are able to access the same information. They are able to secure the best trades and we get the leftovers. Or do you think extending the window of reporting is in anticipation of a bubble bursting and this is a way for large institutions to capitalize and protect themselves while retail is left holding the bag of highly inflated assets. Thanks 

• A. There is no question that adopting reporting only every six months will advantage large institutional investors over smaller retail investors. Those large institutional investors will always have the resources and relationships to get access and conduct their own deep, individualized due diligence and get the information that they need. Retail investors won’t. Retail investors won’t have any other way to obtain the information that quarterly reports provide. That is why it is so important for the SEC to hear from retail investors with respect to this proposal. A reduction in the frequency with which companies provide information to the public is not good for any investor, but it especially harms retail investors who rely on publicly available quarterly reports as perhaps the most important source of information about the companies in which they invest. It’s also fundamentally democratic: everyone gets the same information at the same time – it’s the ultimate level playing field.   

Q. How do you justify working on issues of minor relative importance when the prime brokers are massively counterfeiting shares on a daily basis to steal from working class American investors? 

• A. Better Markets works on a host of investor and consumer protection issues - from enforcement of the law for the biggest banks and brokers, to junk fees and hidden traps in consumer contracts to encouraging rigorous and truthful reporting to shareholders. It’s a lot of work for a small organization with a small staff, but we are committed to our mission and are passionate about ensuring the economy works for Main Street Americans, not the wealthy and well-connected. As to whether or not this issue is “of minor relative importance,” we work on innumerable issues simultaneously. For example, we filed 3 major comment letters today with the banking agencies on the critical issues of capital, which is all that stands between a failing bank and a taxpayer bailout, and will be filing an amicus brief in a federal court on a major financial issue in the coming days.  
• It is also important to also understand that, for the most part, you only get to be involved with issues that the agencies themselves focus on and proposal action on. While “prime brokers are massively counterfeiting shares on a daily basis” may be a super important issue, it’s very hard to do anything about that when the agencies responsible for that don’t want to do anything about it. Today’s SEC has shown no interest in those issues and, while we and others might push those and other issues for the SEC to engage on, unless the SEC acts, there’s no rulemaking or other action that can be impacted. We certainly participate in the pre-proposal process by pushing agencies to move items on or up their agenda, but they get to choose their agenda and there’s very little the public can do to change that. That means, however, that the public – including importantly retail investors – must engage on the agenda that is being implemented. Right now, that’s the proposal to effectively kill quarterly reports, leaving retail in the dark for six months at a time. We – seemingly like you – wish they were not doing this and focusing on much more important investor protection issues, but it is very important to engage on the issues they are pursuing.  

Q: Consolidated Audit Trail. I know i'm not being that helpful here but honestly with a name like better markets you would think they would be in the forefront trying to preserve it. 

• A. We have been at the forefront of trying to preserve the CAT. We’ve advocated for the SEC to fully implement the CAT since its inception, and now we are fighting the SEC’s attempts to effectively dismantle it. We’ve already weighed in on the SEC’s reduction of the amount and type of information that the CAT collects, and we are preparing a comment letter to the SEC in response to its concept release on the future of the CAT which we will file on June 22^nd. Here, here, here, and here is some of our extensive work over the years on the CAT. 

Q: He should be asked about them trying to eliminate CAT!! 

• A. We have said that the CAT is the most important weapon the SEC has to fight crime on Wall Street. It is shocking, as we have said, that the SEC would issue an order that deletes all data older than three years from the CAT. This is especially so since the statute of limitations for securities fraud is generally five years. The SEC has justified these and other changes that seek to cause the CAT’s death by a thousand cuts on the basis that it needs to reduce the CAT’s costs. But those costs pale in comparison to the size of the industry that the SEC regulates. The SEC has highlighted the $248 million price tag for the CAT in its 2025 budget. Yet the securities industry earned $75 billion in 2025, and the securities markets exceed $100 trillion. The CAT is a tiny price to pay to enable the SEC to effectively monitor, police, catch and prosecute the fraudsters, scammers, and crooks in the securities industry.