Bloomberg Law Publishes Article by Investment Management Counsel David Tittsworth Discussing SEC Staff Guidance

On Sept. 13, SEC Chairman Jay Clayton issued a public statement reiterating the Commission’s longstanding position that “all staff statements are nonbinding and create no enforceable legal rights or obligations of the Commission or other parties.” Investment management counsel David Tittsworth authored an article titled “Putting SEC Staff Guidance in its Place” published by Bloomberg Law Securities Law News on Oct. 17 that reviews how Clayton’s recent statement fits in with broader themes of regulatory reform that have been articulated by the White House, Congress and numerous federal agencies. Mr. Tittsworth’s article includes a discussion on the SEC’s decision to review proxy voting issues, consistency with prudential regulators, also summarizing the bigger picture within which Mr. Clayton’s statement falls, and takeaways on what it may mean for SEC Staff Guidance.