Concurring opinion filed by Circuit Judge Pillard.
Edwards, Senior Circuit Judge.
On December 19, 2018, purportedly acting pursuant to its authority under the Securities Exchange Act of 1934 ("Exchange Act"), 15 U.S.C. § 78a et seq., the Securities and Exchange Commission ("Commission" or "SEC") adopted a Pilot Program, denominated Rule 610T, reprinted in Joint Appendix ("J.A...
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