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October 25, 2022

Better Markets Joins Senators Applauding SEC Rulemaking & Addressing Issues Raised About Notice and Comment Periods

WASHINGTON, D.C.— Dennis Kelleher, Cofounder, President, and CEO, issued the following statement regarding a letter he sent today to SEC Chair Gary Gensler addressing issues raised in a letter he received from twelve U.S. Senators:

“Twelve Senators recently sent SEC Chair Gary Gensler a letter highlighting the importance of the work of the agency and its notice and comment periods for rulemakings.  In a letter we sent today to the SEC Chair, we agreed with the Senators’ recognition that the SEC’s mission of ‘protecting investors, facilitating capital formation, and maintaining fair, orderly, and efficient capital markets is fundamental to the functioning of our economy.’  In fact, it is largely thanks to the SEC’s pursuit of these goals that the US has the broadest, deepest, and most liquid securities markets in the world.

“But the preeminence of the US capital markets is not guaranteed. It depends vitally on investors’ confidence in the integrity and stability of those markets.  And that confidence hinges on the type of investor protections and stability measures that the SEC is constantly working to implement and enhance through the rulemaking process.  That means ensuring that our public and private market structures, trading platforms, investor protections, corporate governance requirements, and disclosure regimes are all fair, transparent, and stable.  Those actions result in well-regulated markets that investors can trust.

“As an organization that has participated in more than 300 rulemakings at the financial regulatory agencies (including almost 150 at the SEC) since being founded in 2010, we also agree with the Senators about the importance of the notice and comment periods associated with all agency rule proposals: ‘Adequate input and public comment is central to ensuring that the SEC’s rules and regulations reflect the perspectives and needs of all stakeholders.’  As we explain in our letter, the volume and pace of the SEC’s current rulemaking is consistent with the last three Chairs and not only follows the law when it comes to comment periods but also typically provides comment periods that extend well beyond the minimum required timeframes.

“Finally, anyone interested in the continued vitality and integrity of our capital markets must recognize that the SEC’s rulemaking agenda is dictated by the need to address serious gaps and weaknesses in the current regulatory framework. That agenda unfortunately grew after four years of neglect if not backsliding during the prior administration.  Adding to this formidable challenge is the plain fact that the financial markets are constantly evolving and presenting new regulatory challenges, often engendered by new technologies, and the SEC simply must be on the frontlines of those changes if it is to fulfill its statutory mission.”

Our letter to Chair Gensler is available here.


Better Markets is a non-profit, non-partisan, and independent organization founded in the wake of the 2008 financial crisis to promote the public interest in the financial markets, support the financial reform of Wall Street and make our financial system work for all Americans again. Better Markets works with allies—including many in finance—to promote pro-market, pro-business and pro-growth policies that help build a stronger, safer financial system that protects and promotes Americans’ jobs, savings, retirements and more. To learn more, visit

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