April 1, 2013
Third-year McGeorge student Erica D. Greilich has filed a public comment with the Securities and Exchange Commission (SEC) concerning its proposed rulemaking, Eliminating the Prohibition Against General Solicitation and General Advertising in Rule 506 and Rule 144A Offerings, 77 Fed. Reg. 54,464 (2012) (to be codified at 17 C.F.R. pts. 230, 239). The comment is available on the SEC website.
Greilich's submission originated as her work product in an advanced research seminar, Current Issues in Securities Regulation, taught by Distinguished Professor Michael P. Malloy. One of the primary objectives of the seminar was to give the students exposure to and experience in the techniques and skills required in preparing a public comment. Greilich not only gained practical experience during the seminar; she achieved a rare honor of having her comment included on the SEC's website.
In addition to participation in sessions focusing on current issues, including broker-dealer and market regulation, investment company regulation, state securities laws, and transnational securities regulation, each student in the Current Issues in Securities Regulation seminar was required to select a pending SEC notice of proposed rulemaking and prepare a public comment on the proposal. The draft comment letters are being presented at seminar sessions in the last six weeks of the course. The first of those sessions featured the comment letter drafted by Greilich.