Boyd School of Law. The views expressed in this report are his own and not made on behalf of the University of Nevada, Las Vegas. He is a member of the PIABA Board of Directors. Portions of this report are drawn from his prior writings on the subject including a law review article advocating for changes in the appointment process for FINRA’s Board of Governors. See Benjamin P. Edwards, The Dark Side of Self-Regulation, 85 U. CINN. L. REV. 573 (2017).