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Comment Letters on SEC Proposed Rules

Comment Letters on SRO Proposed Rules

Legislative Update

S7-31-99
Proposal: Rel. #: File #: Comments Due: # Letters to Date:
Insider trading rules addressing selective disclosure, "use versus possession" and family relationships. 33-7787; 34-42259; IC-24209 S7-31-99 3/29/00 94

Letters Released June 12-23: Date: Position:
Ass'n. of the Bar of the City of New York 6/22/00 The New York bar association agrees that the SEC should clarify the law applicable to insider trading, but believes that proposed rule 10b5-1 is overbroad. The bar does not believe that the proposed rule is the best of the possible alternatives and suggested two other alternatives: deferring to the test adopted by the Adler court or allowing case work to develop on its own before trying to codify it with rulemaking.
Securities Industry Ass'n. 6/15/00 SIA believes that this regulation will discourage the flow of corporate information into the market. In an additional letter, responding to Commissioner Hunt's speech on this regulation, SIA argues that this regulation raises as many new issues as it resolves.

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