Kelley Drye Corporate Partner Bruce Kraus
argues in this article that the agency’s response to successful challenges to its rules has produced real progress in the SEC’s rulemaking process as well. The SEC has refined its internal processes and improved its work product, albeit in ways that Congress and the courts may not have precisely directed. John Coates and many others sound a call for change at the SEC. This Essay demonstrates that the change they’ve been waiting for is occurring now.
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