Comment Text:
I am referencing RIN 3038–AD05 in this comment.
I support the OccupySEC letter and want to add something else.
No regulator from the SEC should be allowed to work in the field of securities and banking for 10 years from leaving a position in the agency. The law firms in DC have built quite a business around plucking the top folks from government and placing them in partnership. Where the seasoned former regulator now partner can turn around and select from the associate lawyers in the firm to send into SEC positions.
Here is where the conflict of interest starts. Those new regulators will make baseball player bucks if they please the partners who defend clients in front of the agency.
When the newly minted regulators are ready for picking, they know that a lucrative life awaits them if they just please the law partners, who are mostly former regulators. This environment is incestuous and is the reason for the herd mentality that pervades DC and the SEC in particular.
