SEC Takes Another Pasting

The US Chamber of Conference has released a 92-page report analyzing the effectiveness of the SEC's regulatory guidance programs, including:

- no-action letters
- exemptive orders
- SRO rules

The report, written by former SEC Secretary Jonathan Katz, concludes that "obtaining guidance or key decisions from the SEC through these processes is increasingly difficult and unpredictable," and recommends:

- clarification of review standards
- firm statutory response deadlines
- a more transparent process