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https://d1d329da-dbb0-4cc9-b461-d7bd4ad09b4e.usrfiles.com/ugd/d1d329_13b9948593544d9d8d73e17185af1591.pdfWe write in strong support of your recent comments indicating that the Securities and Exchange Commission (SEC or Commission) will significantly limit its collection of retail investors' personally identifiable information (PII) as pait of the Consolidated Audit Trail (CAT). We welcome your statement that the Commission will not require retail investors' Social Security numbers to be collected and stored in the CAT. We appreciate the Commission's ongoing work on the CAT and agree that it is important for regulators to be able to oversee the capital markets on a consolidated basis. However, we strongly believe that the CAT can, and should, fulfill its intended purpose without collecting Main Street investors' PII.
Yet that's just what the exemption order being appealed does.In the suit, the ASA requests an alternative approach to the CAT’s generation of a customer ID that does not require broker-dealers to report individual clients’ Social Security or taxpayer identification numbers to the CAT.
It goes on to say that use of the CAT Customer ID (CCID) "allow[s] the elimination of SSNs from the CAT."Participants seek exemptive relief from ... the CAT NMS Plan (1) to allow for an alternative approach to generating a CAT Customer ID (“CCID”) without requiring Industry Members to report individual social security numbers or tax payer identification numbers collectively, “SSNs”) to the consolidated audit trail (“CAT”) (the “CCID Alternative”); and (2) to allow for an alternative approach which would exempt the reporting of dates of birth and account numbers associated with natural person retail Customers to the CAT ...
[T]his Order grants the Participants’ request for exemptions ... subject to certain conditions.
https://www.americansecurities.org/post/lawsuit-filed-against-sec-to-protect-american-investor-privacyThe collection of retail investor PII in no way bolsters the ability of the SEC to oversee equity markets more effectively as the Commission has brought over 400 insider trading cases between FY2011-2019 (averaging over 44 per year). These numbers clearly illustrate that (1) the SEC has no issue in bringing insider trading cases against individuals who violate its rules, and (2) collecting retail investor will needlessly subject millions of American investors to identity theft by cyberhackers for no regulatory benefit.
Harvard’s Reinhart and Rogoff Say This Time Really Is Different:The biggest positive productivity shock we’ve had over the last 40 years has been globalization together with technology. And I think if you take away the globalization, you probably take away some of the technology.
...you probably need a debt moratorium that’s fairly widespread for emerging markets and developing economies. As an analogy, the IMF or Chapter 11 bankruptcy is very good at dealing with a couple of countries or a couple of firms at a time. But just as the hospitals can’t handle all the Covid-19 patients showing up in the same week, neither can our bankruptcy system and neither can the international financial institutions
I indeed hope it is the G-20 and not just the G-19. China needs to be on board with debt relief. That’s a big issue. The largest official creditor by far is China. If China is not fully on board on granting debt relief, then the initiative is going to offer little or no relief. If the savings are just going to be used to repay debts to China, well, that would be a tragedy.
Do you see an inflationary surge at some point?
KR: We don’t know where we will come out. So the probability is, for the foreseeable future, we’ll have deflation. But at the end of this, I think we’re going to have experienced an extremely negative productivity shock with deglobalization. In terms of growth and productivity, they will be lasting negative shocks, and demand may come back. And then you have the many forces that have led to very low inflation maybe going into reverse, either because of deglobalization or because workers will strengthen their rights. The market sees essentially zero chance of ever having inflation again. And I think that’s very wrong.
BM: And what scars are left on economies once the pandemic passes?
CR: Some of the scars are on supply chains. I don’t think we’ll return to their precrisis normal. We’re going to see a lot of risk aversion. We’ll be more inward-looking, self-sufficient in medical supplies, self-sufficient in food.
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