An Exercise in Frustration

I was preparing a comment on today's Congressional panel on dark pools and HFT etc. when I noticed an article on Reuters saying that Goldman Sachs had sent a memo on the subject to the SEC. The memo was "posted on the SEC website", said Reuters. As a diligent reporter I followed up and went to the SEC's website where I then tried to locate said memo. A frustrating hour later I had no more information than I would have had if I'd stood in the street and shouted "What is in the Goldman Sachs memo?" to passersby. With all the banging on the regulators are doing about transparency, the SEC's own website is the most egregious example of opacity I have ever seen. It is an impenetrable collection of officious-looking government documents and EDGAR filings (always a riveting read). To even find a press contact a journalist has to know exactly what the SEC calls the press office (Office of Public Affairs) and where to find the phone number (under contacts, not to be seen anywhere in press releases or news which is customary on websites). A phone call ensued to ask Public Affairs where to find said memo. He was not surprised that I was having trouble and kindly walked me through it. Six clicks later and still not obvious, there it was - at the bottom of another internal memo. It would have been easier to cadge the information from Reuters or Zerohedge (which had it first, I believe). So, Ms. Schapiro, when you next opine about transparency, maybe you should look inward. Information is key when trying to catch criminals and control clever bankers. And if anyone has to mine the information out of the SEC website, the criminals will be laughing all the way to the Cayman Islands before anyone knew they existed. (The memo, BTW, looks like a presentation I saw at Goldman's about a year ago - slightly doctored with its own 'recommendations' for the SEC. Surprise, surprise it favors the status quo for HFT and dark pools. But the banks is down at least on naked sponsored access (DMA), which it thinks could pose systemic risks.)