Comment Letter: The NYSE and the End of the Structural Separation between Regulatory and Commercial Interests of the Exchange

The NYSE transformed into a for profit entity in 2006. As part of the approval process, the NYSE agreed to structurally separate the regulatory function from the business function. In doing so, the NYSE created NYSE Regulation, a non-profit with an independent board, to handle most regulatory matters. During the comment period, a spirited debate arose over the ability of a for profit company to carry out a regulatory mission. Some suggested that the regulatory function was incompatible with a "for profit" motive and that NYSE Regulation should be spun off. Others accepted the proposed structure but called for additional changes designed to reduce the possible influence of the public holding company over the regulatory function. In the end, the SEC approved the structure but with a number of prophylactic safeguards including the requirement that NYSE Regulation have a board consisting of all independent directors (save the CEO) and that directors from the for profit holding company could not make up a majority of the board. More recently, however, the NYSE has proposed to end the structural separation of the two functions and instead put in place a functional separation. The proposal would result in the termination of the delegation agreement between the Exchange and NYSE Regulation and the creation of both a Regulatory Oversight Committee of the Board of Directors of the Exchange and the creation of a Chief Regulatory Officer. This letter examines the history of the separation of the two functions and critiques the NYSE's proposal.

Implementing an Integrated Management System (IMS) at an Aerospace Manufacturing Facility

This project analyzes the challenges, issues, benefits, and lessons learned that several companies experienced while implementing integrated management systems. Based on previous experiences, this paper defines several strategies that an organization should use to increase the probability of implementing an integrated management system (IMS) successfully. Strategies include completing a feasibility analysis, creating a policy, allocating resources, developing objectives, modifying documentation, and creating a continuous monitoring process. Moreover, an organization can reduce potential obstacles by promoting a culture that encourages management commitment and employee participation. Results indicate the implementation of an IMS provides the framework to manage environmental, health, and safety programs effectively. By implementing an IMS, an organization can save time and money, as well as proactively control risk.