SEC Petition Process as a Regulatory Advocacy Tool – Carolyn Walsh

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    In a Compliance Week article on the recent rise in the use of the Petition for Rulemaking process to petition the Securities and Exchange Commission (SEC), Of Counsel Carolyn Wash called the infrequently used process an “expression of frustration that a solution, viewed by some significant part of the market as making makes sense, isn't being proposed.” In the piece, published on October 1, 2013, Ms. Walsh also referred to petitions as “another bite at the apple,” taken by a party when it feels that concerns laid out in comment letters have not been heeded by the SEC.

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