Subject: S7-04-23: Webform Comments from Anonymous
From: Anonymous
Affiliation:

Oct. 29, 2023

The proposed rule doesn't consider:
1. Unintended consequences - Implementing a new regulation might have
unanticipated negative impacts on market players or consumers. These
outcomes may not be apparent until after the rules are in place, and
they can often be difficult to reverse once implemented.
2. Cost of compliance - The cost of implementing and maintaining
regulatory requirements could be high for some companies, leading to
reduced profitability, job losses, or other negative impacts on their
businesses. This is especially true for smaller companies that might
not have the resources to bear these costs.
3. Increased complexity - Regulations can add layers of complication
and bureaucracy that make it harder for investors and industry
participants to understand what they must do, leading to confusion and
potential missteps.
4. Impact on innovation - New regulations might stifle the development
or adoption of new technologies, products, or services by making them
more expensive or difficult to implement. This could result in reduced
competition within an industry.
5. Regulatory capture - There is a risk that regulators may become too
closely aligned with the interests they are meant to regulate, leading
to rules that favor certain companies over others.
6. Unnecessary restrictions on business activities - Some proposed
rules might limit legitimate and beneficial business practices without
providing any real benefit to consumers or investors. This could
hinder economic growth and job creation in affected industries.
7. Lack of flexibility - New regulations may not allow for enough
flexibility in how they are implemented, leading to one-size-fits-all
solutions that do not address the unique needs of different businesses
or markets.
8. Increased market volatility - Some proposed rules could lead to
increased market uncertainty and volatility as investors try to
understand their impact on various industries or companies. This can
make it harder for people to plan for retirement, save for college, or
otherwise manage their finances effectively.
9. Impact on global competitiveness - New regulations might put
U.S.-based firms at a disadvantage compared with foreign counterparts
who are not subject to the same requirements. This could lead to an
exodus of jobs and investment from American companies seeking more
favorable regulatory environments abroad.
10. Impact on small businesses - Small businesses might be
particularly hard hit by new regulations, as they often lack the
resources or expertise needed to comply with complex requirements.
This could lead to consolidation within an industry and reduced
competition overall.