This Article attempts, on the basis of five years of practice and legal development, to pinpoint those areas where the Cross-Border Rules appear to be working; highlight where changes might be beneficial; and suggest possible improvements, reforms, and revisions that would better provide participants with the flexibility that the SEC originally intended. Ultimately, the conclusions and analysis herein, although critical, are not pessimistic. The general purpose of the Cross-Border Rules, and their broad outline, are sensible. The devil is mainly in the details.

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