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Crafting Comment Letters: Teach Policy, Develop Skills, and Shape Pending Regulation

18 Pages Posted: 19 Aug 2016 Last revised: 9 Feb 2017

Nicole G. Iannarone

Georgia State University - College of Law

Benjamin P. Edwards

University of Nevada, William S. Boyd School of Law

Date Written: August 18, 2016

Abstract

This essay unpacks the regulatory comment letter process and how to incorporate it into the law school curriculum. Participating in live rulemaking offers unique opportunities for students, from mastering the substantive area of law, developing critical thinking skills, and developing their professional identities and expertise. We describe our own experiences in incorporating students into the regulatory rulemaking process. Because of our focus on securities law, our students review and comment on proposed actions by securities regulators — the Financial Industry Regulatory Authority (FINRA) and Securities and Exchange Commission (SEC). After providing an overview of the pedagogical and practical rationale for incorporating the securities rulemaking process into our courses, we describe how we teach the process to students, from identifying appropriate rules to submitting a comment. We conclude with a discussion of the outcomes and benefits that we and our students experienced after adding the live rulemaking process to our pedagogical toolkits.

Suggested Citation

Iannarone, Nicole G. and Edwards, Benjamin P., Crafting Comment Letters: Teach Policy, Develop Skills, and Shape Pending Regulation (August 18, 2016). Tennessee Journal of Business Law, vol. 18, 2016; Georgia State University College of Law, Legal Studies Research Paper No. 2016-14. Available at SSRN: https://ssrn.com/abstract=2825989

Nicole G. Iannarone (Contact Author)

Georgia State University - College of Law ( email )

P.O. Box 4037
Atlanta, GA 30302-4037
United States

Benjamin Edwards

University of Nevada, William S. Boyd School of Law ( email )

4505 South Maryland Parkway
Box 451003
Las Vegas, NV 89154
United States

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