January 31, 2005
Any modifications to the Rules that eliminate uncertainty are beneficial, such as the proposed 30-day bright line test, which gives the registration period a definitive beginning point, and Proposed Rule 168, which clarifies what information is exempt from sec 2a10. Also, shifting liability to a point sometime before the final prospectus is delviered is logical, since the investor makes the decision to enter into the contract of sale based on all the information preceding devlivery of the final prospectus. Finally, adoption of the acces equals delivery concept is commendable provided that the prescribed means of getting access to a final prospectus do not allow for anything more complicated than one click-through, otherwise the process could be open to abuse.