On November 3, 2004, the Securities and Exchange Commission issued proposed rule release number 33-8501, entitled “Securities Offering Reform” (the “Proposal”), which would represent the most far-reaching reform of the securities offering process since 1998 and, if adopted, would be the most significant reform in decades. The Proposal seeks to reduce the regulation of communications during securities offerings, to allow large companies better and more efficient access to the capital markets, and to change some aspects of liability in the securities offering process....