Public Statements & Remarks

Opening Statement, Second Open Meeting to Consider Final Rules Pursuant to the Dodd-Frank Act

Commissioner Jill E. Sommers

Tuesday, July 19, 2011

Good Morning. Thank you Mr. Chairman and thank you to the teams that have final rules and proposals before us today. I again want to acknowledge the excellent staff work and convey my appreciation to everyone who is working to get these final documents ready for Commission consideration. We are all so grateful to you for your commitment to this enormous challenge. We could not do this without you.

This is the second Commission meeting to consider and vote on final rules, with another meeting to vote on final rules planned for August 4th. Although the final rules we have been considering thus far deal with discrete, stand-alone issues, complex rules dealing with market structure and business conduct standards are on the horizon. Finalizing those rules will be a difficult uphill climb. We are beginning that difficult climb without a plan and I believe that is a mistake.

As I have said many times, formulating and sharing with the public a thoughtful plan on how the Commission will logically sequence its consideration of final rules, along with a transparent implementation plan that will allow for a reasonable phased-in approach, is critical.

I believe we run the risk of unnecessarily increasing uncertainty among market participants by rolling out final rules in a piecemeal fashion, one meeting at a time.

I support the final rules we are voting on today and have a few questions for the teams. But I am concerned about the proposed rules. Both of the proposals were added just a couple of months ago to an already full agenda and are not required by Dodd/Frank. These proposals involve complicated issues that market participants have spent countless hours addressing. I question whether our proposals recognize the complexity of the issues and the amount of work done on sensible industry-driven solutions. As I have said before, I would like to see this Commission finish the job of implementing the requirements of Dodd/Frank before we turn to these discretionary items.

Thank you again to all the teams. I look forward to the discussion of these rules.

Last Updated: July 20, 2011