
One of the great desktop admonitions is “eschew obfuscation”. We interpret that to be a message both to cut needless or unhelpful complexity and to keep it simple. In that spirit, a recent address caught our eye. As described in a December 2019 address by the director of the division of investment management at the SEC[1], the regulatory battlefield includes, as general categories, let alone specific sub-groups: finalized rulings, proposed rulings, exemptive orders, and outreach initiatives.