Top Tweets for #BlueLedger

Filed a 55-page comment with the SEC today in File No. S7-2026-20 opposing the proposed rescission of Rules 611 and 610(e). Full math on this one. The Commission quantifies the benefits of rescission down to the EXACT dollar ($54–77M/year in compliance savings) and leaves the costs to retail investors in prose. That... is the asymmetry the D.C. Circuit struck down in Business Roundtable v. SEC (2011). So.... I built the OTHER side of the ledger. Using the Commission's OWN severity parameters and a Monte Carlo model (see images below) over the unknown exposure fraction, the model produces a BASE CASE of $664M per year in ANNUAL retail-to-wholesaler WEALTH TRANSFER, with a 90% interval of $390M to $1.58B. The break-even is 11.6%: to justify rescission on its own numbers, the Commission must find, ON the record, that fewer than $1 in $9 of retail marketable order flow is actually price-sensitive to Rule 611. It has NEVER stated the number. Right? There are twenty-one objections, now preserved for § 25(c)(1) purposes. My submission includes a reproducible wealth-transfer model and a firm-by-firm verified enforcement docket. Next 60 days should be interesting. #BlueLedger Link to the filed version, comments from the experts and retail welcome. (cover email screenshot also below): https://t.co/i7MFZtMEgu