Global DCA Request to US SEC for Additional Response Time – Amendments to Exchange Act Rule 3b-16 Regarding the Definition of “Exchange” – Global DCA

Global DCA Request to US SEC for Additional Response Time – Amendments to Exchange Act Rule 3b-16 Regarding the Definition of “Exchange”

Global DCA Request to US SEC for Additional Response Time – Amendments to Exchange Act Rule 3b-16 Regarding the Definition of “Exchange”

“Given the brevity of time provided for response (30 days) as well as the importance of this issue, we are deeply concerned that the public comments on the Proposed Rule will lack the number, depth and detail necessary for a fair evaluation of the Proposed Rule. Additionally, such a brief timeline hampers smaller and mid-size firms even more as they lack the critical resources to be able to review and determine the impact on their businesses necessary to respond in any meaningful way. Furthermore, we worry that a rush to judgment would negatively impact the overall effectiveness of a final rule and create unintended consequences damaging to the interests of the United States.” – Global DCA.