October 31, 2019
Subject: File No. S7-19-19 From: Kathleen Crowley, accounting student October 31, 2019 Proposed are changes in requirements for expedited review, especially new rule 0-5(d)(1) which requires that applications for expedited review be substantially identical to previously granted applications for relief. Comment is requested specifically on the following issue: Do these requirements strike the appropriate balance between permitting applicants to seek the relief they need and facilitating the Staff’s prompt review of routine applications? They do. The stated goal is to streamline the process for applications that do not differ materially from others that have already been approved, so that more resources can be allocated to review of applications that do differ in more substantial ways. The proposed change will likely encourage applicants to make sure the relief they seek is when possible very similar to previous applications, so that they can qualify for expedited review. It may be a drawback, having applicants consider ways to seek relief that so closely matches relief already granted. Possibly that consideration might cause applicants to seek relief that is not optimal for their situation. However, this seems to be the only potential problem with the proposed rule change, and since applicants retain the option of applying outside the expedited process, it should be worth the cost. Further, the ability to focus more time and care on applications that are not part of the expedited process means that this cost, itself, is lowered by the proposal. For this reason, the proposed requirements do indeed strike an appropriate balance between flexibility and timeliness in review of routine applications. Thank you for soliciting views on these proposed rule changes, and for your consideration of my opinion. Sincerely, --Kathleen Crowley