Today is a remarkably cold day in New York but that’s done nothing to dampen the spirits of the members and supporters of Occupy the SEC, which had a real influence on the final Volcker Rule, as reported by the Wall Street Journal and The Washington Post, among others.

I’m not saying the Volcker Rule is perfect – in fact Occupy the SEC gave it a C- grade overall. And it was maddeningly delayed. As I’ve mentioned before, Occupy the SEC sued the regulators for the delay, or tried to, but the judge found that they had no standing.

Even so, there’s a clear victory here for Occupy the SEC. The final rule, or at least its preamble, references Occupy the SEC’s public commenting letter 284 times. The rule could have been way worse, and probably would have been without OSEC’s contribution.

Just to get some idea of the other voices in this debate – i.e. the lobbyists – take a look at this graphic on access to the rule-writers by parties interested in influencing the final rule:

I remember those guys in the early days of Occupy, meeting in the cold, drafty, and noisy chambers of 60 Wall Street after work and sitting in a circle going through the proposed Volcker Rule line by line. Nothing could have been more workmanline or hopeful. It was a great example of an Occupy group that was all work and no talk. People who wanted to talk just left them alone. I talked to them briefly about some risk model details for the rules because of my background in portfolio risk.

I even remember talking to them about the chances anybody would even read their letter, never mind take it seriously. They knew the rules, though, and the rules were that the regulators would have to read all the letters, although how seriously they took them was a different matter. They were doing it because they knew it was one of the best shots at having their voices heard. It was an incredible commitment to that ideal.

My conclusions:

Those guys are awesome.

Public commenting is a critical tool.

This wouldn’t have worked without a receptive set of regulators.

This is inspiring and will hopefully help my Occupy group, Alt Banking, plan our next project.

I particularly like the idea of report cards, which Occupy has created for regulation.