Archive for December 30th, 2007

Worm/Wulff Change: A Major Improvement with Some Disappointment

By at 30 December, 2007, 8:42 pm

It has taken a bit of analysis, discussion and interaction with SEC staff, but I am now able to offer some thoughts on the ultimately very positive change (albeit not as far-reaching as hoped) implemented by the SEC with respect to codifying certain positions of the staff under what have been known as the Worm/Wulff [...]

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