Submitted by OSEC to the U.S. Securities and Exchange Commission on February 13, 2012, the 325-page comment letter[REF][REF] was hailed as "amazing", describing how the authors went through the rule "line by line, explaining where it's useless and where it can and should be improved."[REF]
On February 26, 2013, OSEC filed a suit in the Eastern District Court of New York naming the Federal Reserve, the SEC, CFTC, OCC, FDIC, and the U.S. Department of the Treasury calling for implementation of the "Volcker Rule" (Section 619 of the Dodd-Frank Act of 2010) [REF].