February 11, 2022

SEC Rulemaking: New Approach to Comment Periods

Dave blogged last month that the SEC has drawn criticism for proposing rules with comment periods that are shorter than the traditional 60 days, which typically runs from the date that the proposal is published in the Federal Register. On the flip side, it seems to be taking a very long time to get proposals published. As far as I can tell, the proposals on buybacks and Rule 10b5-1 reform still have not made it into the Federal Register – so the comment period clock has not yet started ticking.

For this week’s slew of rulemaking, the SEC seems to be taking a new approach. Comments are due 30 days after publication in the Federal Register OR 60 days after issuance of the proposal, whichever is later. At a minimum, that gives people until April 11th to submit comments on these proposals.

Liz Dunshee