SEC Commissioner: It’s Always Something

First of all, I’d like to thank the people at Compliance Week for giving me the chance to speak here today. Congratulations to all of you for being here as well. I know that all of you are experts in the art of “full catastrophe living” when it comes to compliance efforts on behalf of your respective firms, and I am honored that you pulled yourselves away from the daily crises to be here today. In fact, that’s what I would like to talk with you about today, the art of full catastrophe compliance.

Before I go on, I should remind you that my remarks today are mine alone and do not necessarily reflect the opinions of the Commission, the Enforcement Division or any other staff member.

I would like to start today with pearls of time-worn wisdom from a renowned legal scholar and compliance commentator: Roseanne Roseannadanna. You look a little skeptical. Well, honestly, if ever there were an expert on full catastrophe anything, surely it was Roseanne. As you know (assuming that you, like me, are old enough to remember), Roseanne was one of the late Gilda Radner’s comic creations on Saturday Night Live, along with the equally memorable Baba Wawa, the little old lady Emily Litella ("oh, never mind"), and a hapless teenage nerd in pigtails, Lisa Loopner, who was forever pushing her glasses back up the bridge of her nose. It’s hard to believe, but Gilda Radner’s been gone almost 20 years now — fortunately, she left us some wisdom along with the laughter.

Now Roseanne, you may recall, really was a commentator of sorts. She was a loud, brash and tactless woman with garish outfits and frizzy black hair who appeared alongside the impeccably coiffed Jane Curtin, the frosty news anchor on the Weekend Update segment of the show. Roseanne’s role in the broadcast was to provide editorial commentaries on current social issues. The commentary followed a strict formula: Roseanne would read a letter that was almost always from the same person — Mr. Richard Feder of Ft. Lee, New Jersey. Mr. Feder’s letters usually posed a series of questions about some controversial issue. Like any good commentator, Roseanne knew how to skirt the difficult issues by simply ignoring them. Instead, she focused on Mr. Feder and his home state: “You sure ask a lot of stupid questions for a guy from New Jersey — you belong in New Jersey!” In fact, Roseanne made a lot of derogatory remarks about New Jersey — talk about shooting fish in a barrel! Here’s another disclaimer in the interests of full disclosure, I myself am also from New Jersey.

Anyway, after skewering poor Mr. Feder and my beloved home state (also the home of Bruce Springsteen by the way), Roseanne would start to answer his questions. But her commentary would always veer off into some totally irrelevant, painfully detailed and entirely disgusting description of bodily functions or personal hygiene, often attributed to some famous celebrity. Roseanne would stop herself only to ask “Whaddya tryin’ to do? Make me sick?!” Then she would launch into yet more revolting details. But there was only so much Jane Curtin could take, and she would eventually interrupt the digression: “Roseanne, you’re about to make me sick. What does any of this have to do with the letter?” And this is where the pearls of wisdom came in.

Roseanne would reply in her honking nasal voice: “Well, Jane, it’s always something. If it’s not one thing, it’s another thing, but it’s always something.” And then she would pass along additional commentary by other famous legal and compliance scholars, who coincidentally were also related to her. Usually she quoted her renowned father, but she also cited other scholars, including her Nana Roseannadanna, Aunt Pollyanna Roseannadanna, and her “musically happening cousin, Carlos Santana Roseannadanna.”