Goldman Sachs, in an effort to demonstrate that its clients' interests come first, has unveiled a 39-step "self-improvement" plan that will modify how the investment bank is governed and how it reports financial information. Goldman will report revenue from its own trading and investing for the first time, The Wall Street Journal notes, and new committees will focus on matters like rooting out conflicts of interest and making sure clients understand the risks involved in their transactions with the firm.

Goldman, which emerged from the financial crisis in better shape than many of its peers, has faced withering criticism and public scrutiny throughout the economic downturn. In July, it paid a $550 million fee to settle a Securities and Exchange Commission lawsuit that claimed Goldman misled investors about a mortgage security. The accusations prompted the eight-month internal review that resulted in the new plan.

So, is Goldman's plan serious reform or public posturing? Commentators are generally skeptical:

  • Financials Haven't Changed Much, states The New York Times' Dealbook. The reforms will only provide "a peak behind the curtain," Dealbook explains. Goldman is shedding more light on its hedge fund, private equity, and real estate operations, but it's still keeping its largest business line--Fixed Income, Currency, and Commodities Client Execution--in the shadows.
  • And Financial Redesign Is Fishy, adds Colin Barr at Fortune: "The new setup conveniently emphasizes Goldman's selfless dedication to doing right by others. Fully 52% of revenue in the third quarter is attributed to the new Institutional Client Services segment. When Goldman reported its third-quarter numbers in October, 72% of revenue was under Trading and Principal Investments," a segment that no longer exists.
  • This Is About Improving Goldman's Relationship With Clients, argues the Journal's Brett Philbin. He notes that the word “client” appears 372 times in Goldman's 63-page document, and says this is no accident as the firm seeks to repair its image following the SEC's charges that Goldman defrauded its clients.
  • Of Course Goldman Loves Its Clients! says Dealbreaker's Bess Levin sarcastically: "That business about a buddy system between the prime brokerage and prop desk in order to facilitate front running of client trades? Baseless rumor at best. Sure, there were times when lines were ... maybe occasionally crossed by accident. But that was the old Goldman Sachs. The new Goldman Sachs respects boundaries."
  • There's No Change in Management, points out the Journal's Liz Rappaport: "Some corporate-governance experts have said Goldman Chairman and Chief Executive Lloyd C. Blankfein should step aside or at least give up his post as chairman. Mr. Blankfein's future isn't addressed in the report, but the company has said investors and clients support him."
  • How Long Will The Changes Last? asks Izabella Kaminska at The Financial Times: "Forever shall the bank now be guided by these principles (and by 'forever' we mean until the bank gets into trouble again, in which case expect revisions)."