Let me start by reminding you that my views are my own as a Commissioner and not necessarily those of the Securities and Exchange Commission (“SEC”) or my fellow Commissioners. It is good to be back at SEC Speaks and to know that the content shared here today is available for anyone who may wish to access it. Last time I was here, I talked about the SEC’s “secret garden”—the maze of staff guidance that serves to define practices across the securities industry in a way that may be inconsistent with a plain reading of the rulebook. This guidance is not promulgated through notice-and-comment rulemaking, but appears in ... (full story)