Excerpt: [W]e have very serious concerns about the validity and content of a number of provisions of the Interim Final Rules, as well as the process the Commission employed to issue them. The Interim Final Rules implement provisions of the Gramm-Leach-Bliley Act ('GLB Act') that eliminate the blanket exemptions for banks from the definitions of 'broker' and 'dealer' under the Exchange Act, and replace those exemptions with more specific activity-focused exemptions.  MORE >>