SEC Comments
The Securities and Exchange Commission encourages the public to submit comments on proposed rules during the comment period. All comments are made available to the public and are posted on the SEC’s website.
Academics often submit individual comment letters on proposed rules. Comment letters from law and finance professors have been an important of the SEC comment process, and research by academics is often cited in final rules.
However, particularly given the large number of proposed rules from the SEC, professors often lack the resources or incentives to submit comments. One of the IILF’s goals is to facilitate and promote such comments from professors.
With that goal in mind, we set forth below the most recent rule proposals, along with relevant links. One of the challenges for many proposals is the very large number of public comments. These comments are important, and we provide a link to all of the comments. We also provide a separate link to “Academic Letters,” to highlight them and make it easier for regulators, commentators, and the public to find letters from professors. Although we include the due date for comment letters, we note that the SEC staff often will include letters submitted after the due date.
2022
Listing Standards for Recovery of Erroneously Awarded Compensation, due July 14, 2022 All comments Academic comments
Environmental, Social, and Governance Disclosures, due August 16, 2022 All comments Academic comments
Investment Company Names, due August 16, 2022 All comments Academic comments
Climate-Related Disclosures for Investors, due June 17, 2022 All comments Academic comments
Private Fund Advisers and Amendments Regarding the Definition of Exchange, due June 13, 2022 All comments for S7-02-22 All comments for S7-03-22 Academic comments
Security-Based Swap Execution, due June 10, 2022 All comments Academic comments
Special Purpose Acquisition Companies, due May 31, 2022 All comments Academic comments
Definition of Dealer and Government Securities Dealer, due, May 27, 2022 All comments Academic comments
Removal of References to Credit Ratings, due May 23, 2022 All comments Academic comments
Cybersecurity Risk Management, due May 9, 2022 All comments Academic comments
Reporting of Securities Loans All comments Academic comments
Short Position and Activity Reporting and Proposed Amendments to the National Market System Plan, due April 26, 2022 All comments Academic comments
The Commission’s Whistleblower Program Rules All comments Academic comments
Modernization of Beneficial Ownership Reporting All comments Academic comments
Securities Transaction Settlement Cycle All comments Academic comments
Cybersecurity Risk Management All comments Academic comments
Private Fund Advisers, due April 25, 2022 All comments Academic comments
Pay Versus Performance All comments Academic comments
Amendments to Exchange Act Rule 3b-16 All comments Academic comments
Amendments to Form PF All comments Academic comments
Rule 10b5-1 and Insider Trading All comments Academic comments
2021
Swaps Prohibition Against Fraud All comments Academic comments
Money Market Fund Reforms All comments Academic comments
Share Repurchase Disclosure Modernization All comment letters Academic comment letters
Electronic Recordkeeping Requirements All comments Academic comments
Reporting of Securities Loans All comments Academic comments
Proxy Voting Advice All comments Academic comments
Updating EDGAR Filing Requirements All comments Academic comments
Applications for Orders under the Advisers Act and the Investment Company Act All comments Academic comments
Enhanced Reporting of Proxy Votes All comments Academic comments
Reopening of Comment Period for Universal Proxy All comments Academic comments