In a statement in support of longer comment periods during the rulemaking process, SEC Commissioner Hester M. Peirce explained that an open dialogue with the public is crucial to effective rulemaking. She argued that public comment on the SEC's proposed rules helps the SEC identify potential flaws, which it may not have seen on its own, or alternative solutions to a particular problem.
Ms. Pierce noted that effective dialogue flows only when the SEC affords the commenting public sufficient time to thoroughly review the proposed rules and form detailed opinions. Given the complexity and length of some of these rules, Ms. Pierce stated that 30 days are not sufficient for the public to form fully articulated opinions and advocated for a 60-day time period and a 90-day comment period for more complicated rulemakings or during periods when many rulemakings are outstanding simultaneously.
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