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ASA Urges SEC to Extend Comment Period for 90 Days

WASHINGTON – The American Securities Association (ASA) today sent a letter to the Securities and Exchange Commission (SEC) calling for the extension of the comment periods for every outstanding proposal by a minimum of 90 days.

“The SEC currently has fourteen proposals out for public comment, none of which are required by law,” ASA Head of Government Affairs Kelli McMorrow wrote in the letter. “To date, the SEC has not conducted any type of comprehensive economic or other analysis about the potential costs of these combined rules or how they will impact retail investors, the ability of businesses to raise capital, market integrity, or systemic risk.”

“Robust public input leads to better informed rulemaking and minimizes the possibility that the SEC will have to revisit many of these rules once they are finalized to correct unintended consequences or face a legal challenge,” McMorrow wrote. “We therefore urge the SEC to extend the comment periods for every outstanding proposal by a minimum of 90 days and to conduct a comprehensive examination of the cumulative impact of all the new regulations it is considering.”

In December, prior to additional rule proposals, the ASA sent a letter to the SEC calling for the extension of the comment period. Since then, Commissioner Peirce has also raised concerns that commenters may not have an adequate amount of time to consider how certain proposals might affect, or be affected by, other outstanding proposals.


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