Comment Letters

2025 Comment Letters

• Re: Regulatory Notice 24-17: Request for Comment on Proposed Changes to FINRA Corporate Financing Rules (March 17, 2025)

2023 Comment Letters

• Re: August 30, 2023 C&DI 111.01 re: Form SF-3 Eligibility Requirements (November 17, 2023)

2022 Comment Letters

• Re: Special Purpose Acquisition Companies, Shell Companies and Projections (June 17, 2022)
• Re: Rule 10b5-1 and Insider Trading (April 29, 2022)
• Re: Proposed Rules and Rule Amendments Regarding Private Fund Advisers; Documentation of Registered Investment Adviser Compliance Reviews (April 28, 2022)
• Re: Comments on Modernization of Beneficial Ownership Reporting (April 28, 2022)
• Re: Amendments to Exchange Act Rule 3b-16 Regarding the Definition of “Exchange”; Regulation ATS for ATSs That Trade U.S. Government Securities, NMS Stocks, and Other Securities; Regulation SCI for ATSs That Trade U.S. Treasury Securities (April 18, 2022)
• Re: Share Repurchase Disclosure Modernization (April 13, 2022)
• Re: Comments on Listing Standards for Recovery of Erroneously Awarded Compensation (File No. S7-12-15, Release No. 33-10998) (January 24, 2022)

2021 Comment Letters

• Re: Notice of Proposed Conditional Exemptive Order Granting a Conditional Exemption from the Information Review Requirement of Amended Rule 15c2-11 (a)(1)(i) and the Recordkeeping Requirement of Amended Rule 15c2-11 (d)(1 )(i)(A) under the Securities Exchange Act of 1934 for Certain Publications or Submissions of Broker-Dealer Quotations on an Expert Market (Release No. 34-90769; File No. S7-23-20) (February 12, 2021)
  

2020 Comment Letters

• Re: Notice of Proposed Exemptive Order Granting Conditional Exemption from the Broker Registration Requirements of Section 15(a) of the Securities Exchange Act of 1934 for Certain Activities of Finders (File No. S7-13-20) (November 12, 2020)
  
• Re: Facilitating Capital Formation and Expanding Investment Opportunities by Improving Access to Capital in Private Markets; Release Nos. 33-10763; 34-88321; File No. S7-05-20 (July 27, 2020)
  
• Re: Good Faith Determinations of Fair Value (File No. S7-07-20) (July 20, 2020)
  
• Re: Management's Discussion and Analysis, Selected Financial Data, and Supplementary Financial Information;  Release No. 33-10750; 34-880093; File No. S7-01-20 (June 5, 2020)
  
• Re: Amending the "Accredited Investor" Definition; Release Nos. 33-10734 and 34-87784; File No. S7- 25-19
  (May 22, 2020)
  
• Re: Use of Derivatives by Registered Investment Companies and Business Development Companies; Required Due Diligence by Broker-Dealers and Registered Investment Advisers Regarding Retail Customers' Transactions in Certain Leveraged/Inverse Investment Vehicles (File No. S7-24-15) (May 1, 2020)

2019 Comment Letters

• Re: Concept Release on Harmonization of Securities Offering Exemptions File No. S7-08-19 (October 16, 2019)
  
• Re: Notice of Filing of a Proposed Rule Change to Amend FINRA Rule 5130 (Restrictions on the Purchase and Sale of Initial Equity Public Offerings) and Rule 5131 (New Issue Allocations and Distributions) (File No. SR-FINRA-2019-022) (August 27, 2019)
  
• Re: Board Outreach Initiative-The Role of Fund Directors in Fair Valuation (July 22, 2019)
  
• Re: Securities Offering Reform for Closed-End Investment Companies (File No. S7-03-19) (July 3, 2019)
  
• Re: Fund of Fund Arrangements (File No. S7-27-18) (June 11, 2019)
  
• Re: Notice of Filing of a Proposed Rule Change to Amend FINRA Rule 5110 (Corporate Financing Rule - Underwriting Terms and Arrangements) to Make Substantive, Organizational and Terminology Changes; File Number SR-FINRA-2019-012 (May 30, 2019)
  
• Re: Request for Comment on Earnings Releases and Quarterly Reports; File Number S7-16-18 (March 19, 2019)
  

2018 Comment Letters

• Re: Concept Release on Compensatory Securities Offeings and Sales: Files No. S7-18-18 (November 28, 2018)
• Re: Exchange-Traded Funds: Proposed Rule: File No. S7-15-18 (October 11, 2018)

2017 Comment Letters

• Re: Business and Financial Disclosure Required by Regulation S-K Release No. 33-10064; 34-77599; File No. S7-06-16 (December 15, 2017)

2015 Comment Letters

• Re: Proposed Amendments to Form ADV and Investment Advisers Act Rules (Rel. No. IA-4091; File No. S7-09-15) (September 3, 2015)
• Re: Disclosure of Hedging by Employees, Officers and Directors (Rel. Nos. 33-9723, 34-74232, IC-31450; File No. S7-01-15) (July 8, 2015)
• Re: Request for Public Comment Changes to Exchange Act Registration Requirements to Implement Title V and Title VI of the JOBS Act (Rel. Nos. 33-9693, 34-73876; File No. S7-12-14) (April 10, 2015)
• Re: Request for Public Comments on the Securities and Exchange Commission's Disclosure Effectiveness Initiative - Recommendations on Regulation S-K (March 6, 2015)

2014 Comment Letters

• Re: Request for Public Comments on the Securities and Exchange Commission's Disclosure Effectiveness Initiative (November 14, 2014)
• Re: Comments to Notice of Filing of Proposed Rule Change Relating to Payments to Unregistered Persons (Rel. No. 34-73210; File No. SR-FINRA-2014-037) (November 5, 2014)
• Re: Regulation Crowdfunding (Rel. Nos. 33-9470, 34-70741; File No. S7-09-13) (May 28, 2014)
• Re: Proposed Rules for Limited Corporate Financing Brokers (May 21, 2014)
• Re: Re-Opening of Comment Period for Asset-Backed Securities Release (Rel. Nos. 33-9552, 34-71611; File No. S7-08-10) (May 6, 2014)
• Re: Proposed Rule Amendments for Small and Additional Issues Exemptions Under Section 3(b) of the Securities Act (Rel. Nos. 33-9497, 34-71120, 39-2493; File No. S7-11-13) (April 3, 2014)
• Re: Pay Ratio Disclosure (Rel. Nos. 33-9452, 34-70443; File No. S7-07-13) (March 7, 2014)

2013 Comment Letters

• Re: Amendments to Regulation D, Form D and Rule 156 under the Securities Act (Rel. No. 33-9416; File No. S7-06-13) (December 6, 2013)
• Re: Credit Risk Retention (Rel. No. 34-70277; File No. S7-14-11) (November 12, 2013)
• Re: Cross-Border Security-Based Swap Activities (Rel. No. 34-69490; File No. S7-02-13) (October 2, 2013)
• Re: Money Market Fund Reform; Amendments to Form PF (Rel. No. 33-9408; File No. S7-03-13) (September 30, 2013)
• Re: Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc. Notice of Filing and Immediate Effectiveness of a Proposed Rule Change Relating to Members' Filing Obligations Under FINRA Rule 5123 (Rel. No. 34-69843; File No. SR-FINRA-2013-026) (August 2, 2013)
• Re: Request for Public Comments on SEC Regulatory Initiatives under the JOBS Act Title III - Crowdfunding (March 20, 2013)

2012 Comment Letters

• Re: Potentially Negative Impacts on Human Rights and the Internet Posed by WCIT-12 (October 30, 2012)
• Re: Eliminating the Prohibition Against General Solicitation and General Advertising in Rule 506 and Rule 144A Offerings (Rel. No. 33-9354; File No. S7-07-12) (October 5, 2012)
• Re: Request for Public Comments on SEC Regulatory Initiatives Under the JOBS Act: Title IV-Small Company Capital Formation (September 7, 2012)
• Re: Credit Risk Retention - Use of Participation Interests (August 10, 2012)
• Re: Regulatory Notice 12-27: Corporate Financing Rule: Proposed Amendments to FINRA Rule 5110 Regarding Deferred Compensation Arrangements in Public Offerings and Filing Requirements for Certain Exchange-Traded Funds (July 30, 2012)
• Re: Request for Public Comments on SEC Regulatory Initiatives Under the JOBS Act Title II- Access to Capital for Job Creators (April 30, 2012)
• Re: FINRA Regulatory Notice 12-14 (April 9, 2012)
• Re: Proposed Model Crowdfunding Exemption (March 12, 2012)
• Re: Prohibition against Conflicts of Interest in Certain Securitizations (Rel. Nos. 34-65355, 34-65942 and 34-66058; File No. S7-38-11) (February 13, 2012)