"One criticism of the proposal, such as that stated by dissenting Commissioner Daniel M. Gallagher, is that the rule places a strict liability standard on executives where Congress did not mandate one in the Dodd-Frank Act.... A second point of controversy is the definition of 'executive officers.'... According to Commissioner Gallagher and other critics, the rule's no-fault standard, coupled with the broad definition of who the rule applies to, 'creates the potential for substantial injustice' because 'the rule sweeps far more broadly than the group of individuals ultimately responsible for the financial reporting of the entire issuer."  MORE >>