The regulatory and legislative goal of responding more quickly to market changes is praiseworthy. The goal is not met by giving the market 30 days less time to assess regulatory proposals meant to reflect market changes.

The focus of effective policy making should be on getting things right. Regulators cannot risk pushing through, or being perceived as pushing through, a regulatory agenda quickly.

The minimum consultation period should be set at 90 days and only reduced in the event swift and deliberate actions are needed to improve the stability of the financial system due to a significant disruption in market conditions, such as in periods of acute crisis.

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