The comment period just ended, and the Times has a piece on how active individual banks have been in filing their thoughts (with pictures of your favorite Davis Polk banking law celebrities, if you like that sort of thing). Ordinarily, banks leave these sorts of things to the banking associations. The WSJ has a piece summarizing the comments, and you can get your own taste here (SEC), here (CFTC), and here (Fed). Perhaps most encouragingly, Kim Krawiec, already something of an expert on this sort of commenting, is on the case. It certainly shows how financial lawyers may need to master some of the intricacies of participating in administrative rulemaking.
Administrative Law, Financial Crisis, Financial Institutions | Bookmark
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