On March 17th, the SEC published for public comment a proposal aimed at preserving the application of its existing beneficial ownership rules to persons who purchase or sell security-based swaps after the effective date of new Section 13(o) of the Securities Exchange Act of 1934. The SEC is proposing to readopt without change the relevant portions of Rules 13d-3 and 16a-1. The proposals are intended to clarify that following the July 16, 2011, statutory effective date of Section 13(o), which was added by Section 766 of the Dodd-Frank Act, persons who purchase or sell security-based swaps will remain within the scope of these rules to the same extent as they are now. Comments should be submitted on or before April 15, 2011. SEC Release No. 34-64087. On March 15th and 16th, New York Times columnist Steven M. Davidoff discussed Section 766(e) of the Dodd-Frank Act, noting the competing interests with stakes in its implementation: management, activist shareholders, takeover firms, and the lawyers who represent them. March 15 DealBook Column; March 16 DealBook Column.