July 29, 2010
Gotta bone to pick with Dodd-Frank? Email the SEC!
Posted by Usha Rodrigues

On Tuesday SEC Chairman Mary L. Schapiro announced a new process "making it easier for the public to provide comments as the agency sets out to make rules required under the Dodd-Frank Wall Street Reform and Consumer Protection Act."  A kind of pre-comment period comment period, this move "goes well beyond what is legally required and will provide expanded opportunity for public comment and greater transparency and accountability."  Here are links to the many web-forms you can use to make your voice heard.

I wonder the extent to which criticism of Dodd-Frank's Congressional punting/legit delegation (depending on how you see it) to agencies like the SEC is behind this move. I'm no admin type, but it strikes me as a little odd to give the public an outlet to sound off on everything from the definition of "swap" to disclosures regarding mine safety before the SEC has a chance to frame proposed rules.  I supposed ideally it would serve as a way to test the waters before issuing proposed rules.  In practice, it seems to invite every crackpot out there to weigh in, and then obligate the SEC to respond or justify its silence. 

Administrative Law, Securities | Bookmark

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