Date: December 4, 2015
Issue: SEC Reform
To: Brent J. Fields, Secretary, U.S. Securities and Exchange Commission
Filing Type: Regulatory
Description: The use of the administrative proceedings to adjudicate violations has increased dramatically over the past several years, but the rules of practice have not changed since 1995. CCMC is concerned that the proposal, although a step in the right direction, does not go far enough to leveling the playing field for respondents. Far more extensive amendments are urgently required.