Action Advocacy

September 28, 2026: Alexandros Kazimirov, ICAN's Scholar in Residence, Comment Letter on Innovation Exemption for Tokenized Securities Trading Venues—Recommending Temporary Relief and Regulatory Gradualism

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September 28, 2026: SEC Rule Petition to Protect the Anonymity of Individual Investors in Pooled Investment Vehicles and Withdraw Staff Interpretations Compelling Their Public Identification

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

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

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

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

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

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

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

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

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

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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."

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

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

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

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

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

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Follow Up Responses

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

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

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

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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.

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

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

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

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

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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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