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Action Advocacy

July 20, 2026: Comment Letter Urging Expansion of Shelf-Registration

June 21, 2026: Comment Letter Urging Wind-down of Consolidated Audit Trail Database

June 18, 2026: Featured Nonprofit Organization at Best Ideas Q2

June 8, 2026: Comment Letter in Support of SEC's Proposed Amendments to Allow Optional Semiannual Reporting

February 4, 2026: Urging SEC to appprove reform of pattern day trading minimum equity requirements

December 9, 2025: Correspondence to House Leadership Commending passage of the INVEST Act as beneficial for everyday investors

October 29, 2025: Correspondence to Commission Urging Restraint on Insurance Claims in Cutter Financial Litigation

October 6, 2025: GAIM Ops West Conference, "The Importance of ODD in a Deregulatory Environment."

September 8, 2025: Comment Letter to SEC on the Regulatory Treatment of Foreign Private Issuers

June 13, 2025: Compliance in the Age of AI, "AI and Compliance: The SEC’s Evolving Approach."

May 15, 2025: Securities Enforcement Forum West, moderating debate, "Crypto Task Force Roundtable."

March 31, 2025: Submission to House Financial Services Committee on Legislative Proposals to Increase Investor Access and Facilitate Capital Formation.

February 25, 2025: Michigan State University Law School, "Reining in SEC Regulation by Enforcement."

November 13, 2024: PIPEs Conference, "What you Need to Know About the SEC's Enforcement Campaign Against Convertible Debt PIPE Investors."

September 19, 2024: SEC Hot Topics Webinar in Atlanta, "Reining in Regulation by Enforcement."

May 7, 2024: Testimony before House Financial Services Committee, Capital Markets Subcommittee hearing, "SEC Enforcement: Balancing Deterrence with Due Process"

Follow Up Responses

View Testimony Video

October 30, 2023: Comment Letter requesting the SEC withdraw its proposed custody rule as interfering with investor preferences.

October 25, 2023: Comment Letter urging IRS not to create tax rules impacting determination of digital assets as securities.

October 10, 2023: Comment Letter describing harms to investors the SEC's proposed rule on predictive data analytics would cause.

VIEW Commissioner Peirce Reference to ICAN's Letter

September 18, 2023: Comment Letter Urging PCAOB to withdraw proposed standards that would make auditors responsible for identifying public company noncompliance with laws and regulations.

July 7, 2023: Comment Letter Urging SEC to Withdraw Proposed Rules Expanding Definition of Securities "Exchange"

June 30, 2023: FOIA Request to SEC for Administrative Proceeding Adjudication Memos Improperly Shared with Enforcement Staff

March 31, 2023: Comment Letter Urging SEC to Withdraw Proposed Rules Creating Regulatory Burdens on Commission-Free Payment for Order Flow Trading.

VIEW VIDEO SUBMISSION

November 9, 2022: SEC Rule Petition to Remove Diversity, Equity, and Inclusion Barriers Presented by "Accredited Investor" Financial Requirements.

VIEW VIDEO SUBMISSION

VIEW COURT FILING

August 16, 2022: Comment Letter to California Department of Financial Protection and Innovation regarding regulation of crypto asset-related financial products and services.

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