Public comment letters · U.S. Securities and Exchange Commission
Rulemaking at the U.S. Securities and Exchange Commission is a public process: proposed rules and roundtables are opened for comment, and every letter received becomes part of the permanent public file. Andy Altahawi — the founder of this foundation, an international attorney, member of the bar since 1988, with four decades across global law and the U.S. capital markets — participates in that process on regulations now under discussion in the public discourse. His comment letters are published below; each one is a hyperlink to the full letter as a PDF, so any reader can click through and read it in its entirety on sec.gov.
The Trade-Through Rule and Locked and Crossed Markets Provisions of Regulation NMS
The Commission is revisiting two pillars of Regulation NMS, the 2005 framework that governs how the U.S. national market system routes and prices orders: the trade-through rule (Rule 611), which requires trading centers to honor better-priced displayed quotations on other exchanges, and the provisions restricting locked and crossed markets. The review asks whether rules written for a slower, less consolidated market still serve investors in today’s high-speed, multi-venue structure. Mr. Altahawi’s comment letter is part of the public file for this rulemaking.
Roundtable on Preparations for 24-Hour Trading
As exchanges and trading platforms move toward round-the-clock securities trading, the Commission convened a public roundtable on what a 24-hour market would demand of the national market system — market infrastructure and resilience, liquidity and price discovery outside traditional hours, investor protection, and the operational readiness of issuers, brokers, and clearing systems. Mr. Altahawi’s submission is part of the public record for this roundtable.
Electronic Delivery of Information Under the Federal Securities Laws
This rulemaking considers making electronic delivery the default for the information investors receive under the federal securities laws — prospectuses, reports, and shareholder communications — modernizing a paper-first framework that predates the internet, while addressing access and protections for investors who still rely on paper. Mr. Altahawi’s comment letter is part of the public file for this rulemaking.
Regulation Crypto Assets
Among the most debated questions in today’s public discourse: how crypto assets should be regulated under the federal securities laws. This rulemaking takes up the framework for crypto asset offerings, trading, and custody — where the securities laws apply, how registration and disclosure should work for digital assets, and how investor protection is maintained as the market matures. Mr. Altahawi’s comment letter is part of the public file for this rulemaking.
The letters above are public comments in SEC rulemaking files, published here for transparency. They are the views of Mr. Altahawi alone, not legal or investment advice, and not the views of the foundation in formation. Each PDF is hosted by the SEC at sec.gov as part of the permanent public record.