Yale Journal on Regulation Publishes Article by Jeff Dinwoodie on SEC Rule 15c2‑11 and Fixed Income

On September 25, 2023, the Yale Journal on Regulation published in its Bulletin series an article written by Cravath partner Jeffrey T. Dinwoodie entitled “Fixed Income Securities and SEC Rule 15c2‑11: History, Context, Uncertainties—and a Pathway Forward.” The piece discusses the quandary triggered by the interpretation that the SEC’s broker‑dealer quoting rule, Rule 15c2‑11, applies to fixed income securities. The article examines the regulatory history and recent developments, and proposes a pathway forward for the SEC that would stem market uncertainty—and advance the agency’s tripartite mission.

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