⚖ 2003-era SRO governance adjustments

[JFWooten4]

From #13, we ought address the outstanding items from S7-11-03, S7-39-04, and S7-40-04 inter alia.¹

This is around when the SROs started having their rules reviewed by staff to enforce securities laws, rather than enacting their own preference with retroactive oversight.

Footnotes

1. See laptop hardcopies at 1/3. ↩

[JFWooten4]

Requisites both PNG and Dee Hock's work.¹

Footnotes

1. See Birth of the Chaordic Age, One from Many: VISA and the Rise of Chaordic Organization, and Autobiography of a Restless Mind: Reflections on the Human Condition. The first one should lend enough for TAR2, and the third seems more related to JFWooten4/gratitude-journal#1 a smidge further down the line once going through Corey's Renumerations. ↩

[JFWooten4]

Implications start building up in the 80's here as precedent in the decade after SROs established, per key annual report at 8.

[JFWooten4]

Some good studies here backed by Dr. T as deference:

Traditionally, stock exchanges operated in the form of non-profit mutual or membership
organizations. To the extent market power was not curtailed by competition or regulation,
mutual governance gave specialist or market maker members of an exchange control of the price,
quality and range of services produced by the exchange. Exchange profits were returned to
broker and dealer members in the form of lower access fees or trading profits. Further,
exchanges have long operated as self-regulatory organizations (SROs) with members
contributing their time to governance and self-regulation to make exchanges more effective and
more profitable.

— Commissioner Roberta Karmel, J.D.

[JFWooten4]

The CAT comments on 2026-12 also reference, by implication, the self-cited SRO amendments at n.42 and surrounding text. This has deeper roots in the '98 FINRA decentralization order, which I originally missed. That one is at this admin proceeding.

[JFWooten4]

The draw to bring this to CAT is too good. There is too much we can set up for precedent, which relates directly to the shale donation. I'm changing the tag and referencing the DIR from Nasdaq:

The SRO model is central to making the U.S. equities markets the most powerful economic engine and the most envied capital markets in the world. When Congress developed the SRO model and ordered the SEC to develop a national market system, it understood that the proper balance of competition and regulation was critical to market success. Congress also understood that SROs, as frontline market regulators with direct responsibility for their own markets and members, are uniquely positioned to provide detailed operational oversight that complements the Commission’s broader supervisory role. As Chairman Atkins has recognized, "SROs are a very important part of the overall regulatory structure and one that we must maximize the value of."