View our comment letter: https://www.sec.gov/comments/s7-22-15/s72215-9.pdf
View the proposals: http://www.sec.gov/rules/proposed/2015/33-9973.pdf
View our comment letter: https://www.sec.gov/comments/s7-22-15/s72215-9.pdf
View the proposals: http://www.sec.gov/rules/proposed/2015/33-9973.pdf
A few years ago, we spent a lot of time
This is mostly a classic run-away-with-the-money case, combined with a