If I worked at the SEC, I would not release a major revision of a rule immediately before law school final exams. If I felt absolutely compelled to make such a release, perhaps under threat of Jim Cramer's actually losing it because he couldn't sell restricted securities for a year, I would at least post the full text of the new version of the rule prominently on sec.gov. I would not leave people to be guided by some choppy sentences that have to be cut and pasted where appropriate on the previous version of the rule, buried near the end of a 110-page document that actually is requesting comment on Paperwork Reduction Act burden estimates.

I thought about submitting a comment on the SEC's crappy sense of timing and text -- what about my Paperwork Burden in having to print out both versions and then get out the scissors and glue? (Federal regulations are not a good place to be switching between two online copies to try to create a document.) However, a "professional affiliation" of Angry Student in Last Semester of Law School probably doesn't carry much weight at an agency where the examples for that space are "Professor of Economics, University of Providence /or/ Markets Section Chair, Association of Professional Accountants /or/ CEO, Acme Widget Company."

On the other hand, props to the SEC for getting rid of the various requirements for non-affiliates' sales. That's going to make a certain time-pressured exam go by just a little faster tomorrow afternoon.