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Crafting Comment Letters: Teach Policy, Develop Skills, And Shape Pending Regulation, Nicole G. Iannarone, Benjamin P. Edwards

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This essay unpacks the regulatory comment letter process and how to incorporate it into the law school curriculum. Participating in live rulemaking offers unique opportunities for students, from mastering the substantive area of law, developing critical thinking skills, and developing their professional identities and expertise. We describe our own experiences in incorporating students into the regulatory rulemaking process. Because of our focus on securities law, our students review and comment on proposed actions by securities regulators — the Financial Industry Regulatory Authority (FINRA) and Securities and Exchange Commission (SEC). After providing an overview of the pedagogical and practical rationale for …