OM Financial Life Insurance Company ("Old Mutual") has filed a brief (available here) in response to an order from the U.S. Court of Appeals for the D.C. Circuit. The order (available here ) calls for additional briefing on Old Mutual's petition for rehearing to stay Rule 151A ("Rule"). The issue raised is whether the Rule should be stayed (or vacated), because the SEC has not announced if and when it intends to analyze the Rule's effect on efficiency, competition, and capital formation.

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