Defending Liberty Pursuing Justice ABA AMERICAN BAR ASSOCIATION Section of Business Law 321 North Clark Street Chicago, IL 60610 312.988.5000 email: businesslaw@abanet.org website: www.abanet.org/buslaw March 2, 2005 By E-Mail to: rule-comments@sec.gov Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549-0609 Attn: Jonathan G. Katz, Secretary Re: Securities Offering Reform Release Nos. 33-8501 and 34-50624 (File No. S7-38-04) Ladies and Gentlemen: This letter is submitted on behalf of the Committee on Federal Regulation of Securities of the American Bar Association’s Section of Business Law (the “Committee”) in response to the request of the Securities and Exchange Commission (the “Commission”) for comments on Release Nos. 33-8501 and 34-50624, dated November 3, 2004 (the “Release”). The Release sets forth proposals (the “Proposal”) that would modernize the registration, communications and offering processes under the Securities Act of 1933, as amended (the “Securities Act”), and continue integration of disclosure processes with the Securities Exchange Act of 1934, as amended (the “Exchange Act”). The comments expressed in this letter represent the views of the Committee only and have not been approved by the American Bar Association’s House of Delegates or Board of Governors and, therefore, do not represent the official position of the ABA. In addition, this letter does not ...
Voir