Carl Ayers
"The proposal seeks to curb potential abuses of our rules and enhance transparency for investors, while not unduly restricting issuer and individual trading in a ...
"The goal of the rule is to help ensure that an insider does not have MNPI at the time they make a trade"
"I support today’s proposal to address potential abuses of Rule 10b5-1(c) trading arrangements. The proposed cooling-off periods of 120 days for officers and directors and ...
"Not only is 45 days shorter than our customary comment periods, which have typically been 90 or at least 60 days, these brief comment periods ...
"It wasn’t just Archegos and AIG, though. In 1998, Long-Term Capital Management failed, bringing with it a $100-billion balance sheet and more than $1 trillion ...
"Today’s proposal also includes a rule aimed at protecting the independence and objectivity of security-based swap entities’ chief compliance officers (CCOs) by prohibiting actions to ...
"The proposed rule would seek to safeguard the independence and objectivity of a security-based swap entity’s CCO by preventing the personnel of that entity from ...
"Proposed Rule 10B-1 likewise may serve to squelch legitimate market activity. It requires firms to report publicly large security-based swap positions, along with their positions ...
I also have concerns about proposed Rule 10B-1 regarding public large position reporting
"As you work on and advocate for policy to encourage divestment from carbon intensive activity, it is critical to consider the growing expansion of the ...