# Friday, April 30, 2010

Earlier this week I wrote about how the start-up culture could be killed in Europe if some proposed financial reforms were to be enacted. In the United States last week the SEC put out a lengthy proposal for the regulation of asset backed securities. After reading the summaries and reading this blog, I discovered this part of the regulation:

“We are proposing to require that most ABS [asset backed securities] issuers file a computer program that gives effect to the flow of funds, or “waterfall,” provisions of the transaction. We are proposing that the computer program be filed on EDGAR in the form of downloadable source code in Python. … (page 205)” (Emphasis mine.)

Wait, Python? Should the government be telling us which technology to use? Isn’t this what standards and interoperability are all about? Publish a standard and then require that the software at each issuer adheres to it?

I don’t want to debate which is better: Python, Java, .NET, etc, I don’t care which platform the issuers use. Let their CTOs decide, not the government. The government should set technology standards and guidelines (which most of the proposed regulation does in fact do) but not dictate the programming language used. What if the asset backed security issuer is a Java shop? Microsoft shop? (Most are since Excel/VBA is the #1 application development platform on Wall Street.) A Rails shop? Won’t this shoot up their costs as they scramble to write new software in Python? Introduce a lot of bugs that hackers can exploit?

Seven years ago I testified in front of the New York City Council against a proposed regulation that would have required all city agencies to use Open Source Software since it was “free.” That regulation failed. Hopefully this regulation will also fail.

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Friday, April 30, 2010 10:08:27 AM (Eastern Daylight Time, UTC-04:00)
I don't think that it is unreasonable for them to specify what language the VC is to model the flow of funds in.
Friday, April 30, 2010 11:26:39 AM (Eastern Daylight Time, UTC-04:00)
I agree with the above comment. The SEC appears not to be regulating a product in this case, just a means of disclosure. Seems benign to me. Have I got this wrong?

"Hopefully this regulation will also fail. "

Just because of this provision? What about the rest of the proposal?
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