Mar. 29, 2023
March 29, 2023 Which Commission staffer(s), likely a manager, thought this was a good idea when they made this proposed rule recommendation regarding the third-party automated compliance system to the Commission? To be fair, all policy is directed by the Commission as they are the only ones appointed by the President and confirmed by the Senate with a right to vote on this proposal. So point the fingers at them. I'm a little surprised they gave us, the talented staff of the SEC, an opportunity to comment. The release made clear they were merely doing us a favor, contrary to typical Administrative Procedure Act protocols, by allowing public comment. How kind. They're usually busy catering to other interests and not their employees. There used to be a time when staff actually made well thought out recommendations and they were taken seriously by those in \"power\". Notice the quote marks around \"power\". Now a single Commissioner sitting near their fireplace tells the staff what recommendations to make right back at them ... kind of like an echo chamber. Nice artwork on the mantle at least. Or maybe that Commissioner who is most favorable towards the big crypto industry can figure out a way to exempt employee reporting under this rule ...since they prefer exemptions to regulation and oversight generally. I speculate someone, the aforementioned manager in a non-mission critical role, thought it would be great to give tax dollars to a contractor for a job the Office of Ethics Counsel should be doing internally. Perhaps the same or similar person who thought employees in non-mission critical roles who have nothing to do with securities regulation and investor protection should be entitled to SK scale salaries instead of GS scale salaries despite not being securities professionals the SK pay scale was meant for (licensed attorneys, accountants, fraud examiner, PhD economists)? A \"managing executive\" type or similar? Which according to publicly accessible websites are the highest paid employees at the Commission despite not practicing in the field of securities law, accounting, economics, or regulation as they make their internal feifdoms grow with \"great\" ideas like this proposal. Who, according to publicly accessibly websites, generally only have a bachelor's degree, but run an agen cy of professionals with JDs, CPAs, PhDs, like we are assembly line workers in a factory. These \"managing executive\" type jobs (and similar) that could only exist in government. These people who could never find a private sector job like countless enforcement managers like to get at big law firms. Shame Someone opposed to telework, but participates in telework themselves? Definitely someone opposed to telework (because landlords who are contractors need rent and the managers want to feel \"powerful\" over others making them come into the office).... while teleworking to the max themselves. Great example setters. What a great idea this proposal was (no, not really).... Like using self imposed travel regulations to force employees back into the office for 2 days, but then revoking the travel policy soon after. Crafty. See https://www.flra.gov/node/79433 . Can we get more transparency and information when this rule-making gets re-proposed? They'll probably just adopt because they don't care about staff. That is crystal clear. So many questions about this rule-making. Will the contractor be complying with the same ethics rules that SEC staff does? Or will they just know who the SEC is investigating in a possible enforcement case and trade with that information in mind? If a contract gets awarded, perhaps there can be a review of how this all started. What a bad idea this proposal was Wow. It's up there with \"presence with a purpose\" and \"8-2\" as ideas of the century. Will we get hacked? Will we be compensated once we are hacked? I'm guessing not. But there isn't enough answers in the release so all we can do is guess. It is sad to see the low level of detail in this proposal. No discussion of cyber security? Tisk tisk. Please don't approve it. Also, why isn't the union commenting? What are we paying them dues for? Seriously. Lets not let them off the hook. Silence from them.... what a waste of dues. No letter or advocacy from them? Maybe it will come at the deadline. Maybe.