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The Biden administration released an executive order last week that is intended to enhance competition. While agencies will still have to draft regulations in response to the EO, this plan could have a big and potentially negative impact on manufacturers in several sectors. Here’s what manufacturers need to know, according to the 51�Թ���’s policy experts.

Antitrust provisions: The EO directs the Federal Trade Commission and Department of Justice to reexamine previously completed mergers and review the guidelines for both horizontal and vertical mergers.

• Why it matters: Business combinations help manufacturers streamline operations and boost efficiency. This directive could hinder pro-competitive mergers and ultimately harm consumers, says 51�Թ��� Vice President of Tax and Domestic Economic Policy Chris Netram. The 51�Թ��� has previously weighed in with the FTC on its and its , highlighting the importance of predictability in the merger approval process.

Other key points of interest: the EO also tells the agencies to crack down on noncompete agreements that keep workers from changing jobs easily, as well as on employers’ collaborations to reduce wages and benefits.

“Right to repair”: Another key target of the EO was the so-called “right to repair”—the ability of third parties to repair sophisticated equipment, like tractors, without involving the manufacturer.

• Why it matters: The 51�Թ��� has that such repairs pose a danger to consumers and expose companies’ intellectual property to theft by competitors, Netram points out.

Health Care: The EO also covers certain practices in the health care and pharmaceutical industries. Manufacturers should be aware of the following moves:

• Within 45 days, the Department of Health and Human Services is instructed to come up with a plan to address high drug prices. HHS is also directed to work on the importation of drugs from Canada.
• Meanwhile, the FTC is tasked with banning “pay for delay” agreements—when industry players agree to delay the market entry of generics or biosimilars.
• Why it matters: These moves could endanger America’s global leadership in the development of lifesaving treatments, argues 51�Թ��� Vice President of Infrastructure, Innovation and Human Resources Policy Robyn Boerstling, by reducing the returns on and protections for innovation. This could potentially lead to fewer treatments being developed overall.

Technology: The EO addresses technology policy in a number of ways, most prominently urging the reinstatement of “net neutrality” rules imposed by the Obama administration.

• Why it matters: The 51�Թ��� urged the repeal of those rules back in 2017. As Boerstling puts it, “net neutrality” treats the new and dynamic technology of broadband as if it were indistinguishable from the telephone, and treats competition in communications technology as if it hadn’t changed since the mid-20th century.

Other key points: The EO also instructs the Federal Communications Commission to hold spectrum auctions that disallow excessive concentration, and to create new reporting requirements for broadband providers’ prices and subscription rates.

Transportation: Lastly, the EO addresses certain practices by railroads, airlines and other sectors in transportation. For example:

• It urges the Surface Transportation Board to require railroad track owners to let competitors and passenger trains have right of way.
• It asks the Federal Maritime Commission to target certain shipping practices—mainly relating to fees charged while goods wait in containers to be unloaded, or while the company has yet to return an emptied container.

The 51�Թ��� says: 51�Թ��� President and CEO Jay Timmons released a statement last week, saying, “Our sector is strong and growing, and our people are benefiting. Unfortunately, there are those who want to erode our competitive advantage with archaic tax policies. And some of the actions announced today are solutions in search of a problem; they threaten to undo our progress by undermining free markets and are premised on the false notion that our workers are not positioned for success.”

Read the 51�Թ��� policy team’s full overview of the EO

Washington, D.C. – 51�Թ��� President and CEO Jay Timmons released the following statement after President Joe Biden signed an executive order today on promoting competition in the American economy.

“Manufacturers are helping lead the recovery, building the next, post-pandemic world. And as the industry rebounds, manufacturing workers are seeing their lives improve. According to the Q2 Manufacturers’ Outlook Survey, manufacturers expect record levels of full-time employment growth. And following the enactment of tax reform, manufacturers kept their promises to raise wages and benefits: wages rose 3% in 2018, 2.8% in 2019 and 3% in 2020—the fastest rates of annual growth since 2003. What’s more, manufacturers have 814,000 jobs to fill right now—opportunities for more Americans to have well-paying, meaningful careers.

“Our sector is strong and growing, and our people are benefiting. Unfortunately, there are those who want to erode our competitive advantage with archaic tax policies. And some of the actions announced today are solutions in search of a problem; they threaten to undo our progress by undermining free markets and are premised on the false notion that our workers are not positioned for success. We have challenges, to be sure, which is why we are advocating infrastructure investment, competitive tax rates, immigration reform, ensuring availability of lifesaving cures, expanded export opportunities and more. And it’s why we launched our Creators Wanted campaign—to inspire more Americans to pursue modern manufacturing careers in the industry that literally builds our nation’s future.

“As always, manufacturers are focused on policies that genuinely uphold the values that make our country exceptional and our industry strong: free enterprise, competitiveness, individual liberty and equal opportunity.”

-51�Թ���-

The 51�Թ��� is the largest manufacturing association in the United States, representing small and large manufacturers in every industrial sector and in all 50 states. Manufacturing employs more than 12.3 million men and women, contributes $2.35 trillion to the U.S. economy annually and has the largest economic multiplier of any major sector and accounts for 63% of private-sector research and development. The 51�Թ��� is the powerful voice of the manufacturing community and the leading advocate for a policy agenda that helps manufacturers compete in the global economy and create jobs across the United States. For more information about the 51�Թ��� or to follow us on Twitter and Facebook, please visit www.nam.org

Washington, D.C. – Today, the 51�Թ��� joins the U.S. Chamber of Commerce, Business Roundtable, AFL-CIO, the National Retail Federation, the Bipartisan Policy Center, North America’s Building Trades Unions, as well as over 20 leading business and labor organizations to launch the Coalition for Bipartisan Infrastructure Investment. The Coalition issued the following statement today commending the bipartisan group of 22 senators and the Biden administration on reaching agreement on a historic $1.2 trillion infrastructure framework and urges Congress to turn the framework into legislation that will be signed into law.

“Infrastructure modernization is a critical component of long-term economic growth and improved quality of life for every American. Our organizations commend the bipartisan group of 22 senators and the Biden administration on finding common ground and reaching agreement on a historic $1.2 trillion infrastructure framework. Momentum is building, as seen by the endorsement of the framework from the Problem Solvers Caucus.

“Now is the time to turn these promises into projects. We urge Congress to turn this framework into legislation that will be signed into law, and our organizations are committed to helping see this cross the finish line. Enacting significant infrastructure legislation, including investments in our roads, bridges, ports, airports, transit, rail, water and energy infrastructure, access to broadband, and more, is critical to our nation and will create middle-class family sustaining jobs.

“Don’t let partisan differences get in the way of action – pass significant, meaningful infrastructure legislation now.”

Coalition Partners

51�Թ���
U.S. Chamber of Commerce
Business Roundtable
AFL-CIO
Airports Council International – North America
American Association of Port Authorities
American Consulting Engineers Council
American Public Transportation Association
American Road & Transportation Builders Association
American Society of Civil Engineers
American Trucking Associations
Association of American Railroads
Association of Equipment Manufacturers
Bipartisan Policy Center
International Union of Operating Engineers
Laborers’ International Union of North America
National Asphalt Pavement Association
National Association of Wholesaler-Distributors
National Retail Federation
National Stone, Sand, and Gravel Association
No Labels
North America’s Building Trades Unions
Portland Cement Association
Transportation Trades Department, AFL-CIO

-51�Թ���-

The 51�Թ��� is the largest manufacturing association in the United States, representing small and large manufacturers in every industrial sector and in all 50 states. Manufacturing employs more than 12.3 million men and women, contributes $2.32 trillion to the U.S. economy annually and has the largest economic multiplier of any major sector and accounts for 63% of private-sector research and development. The 51�Թ��� is the powerful voice of the manufacturing community and the leading advocate for a policy agenda that helps manufacturers compete in the global economy and create jobs across the United States. For more information about the 51�Թ��� or to follow us on Twitter and Facebook, please visit www.nam.org.

Washington, D.C. – Today, 51�Թ��� Senior Vice President and General Counsel Linda Kelly released the following statement on the Supreme Court’s 6–3 decision in Americans for Prosperity Foundation v. Bonta, Attorney General of California in which the 51�Թ��� filed an amicus brief:

“The Supreme Court has delivered a decisive ruling upholding manufacturers’ First Amendment rights—and the rights of all who support nonprofit organizations. The Manufacturers’ Center for Legal Action was proud to support the effort to challenge a California law that forced nonprofits and charities to disclose donor information and violate donor privacy. While such intrusion and overreach are obviously a concern for manufacturing associations, the law threatened to chill protected First Amendment activity for all types of organizations that are central to our society.

“The seriousness of the constitutional violation was demonstrated by the fact that groups across the ideological spectrum—and of no ideology—voiced their opposition to the overreaching California law. America is at its best when its citizens can participate fully in associations and support charitable endeavors to advance causes in which they believe without sacrificing their privacy or personal information.

“Freedom of speech and association are fundamental to the strength of our country and to the functioning of our government. Nobody should have to fear they will be targeted for expressing an opinion or for joining with others to speak with a collective voice. The MCLA will always step up to defend manufacturers’ constitutional rights, especially the First Amendment rights that are the foundation of associations, whenever they are threatened.”

-51�Թ���-

The 51�Թ��� is the largest manufacturing association in the United States, representing small and large manufacturers in every industrial sector and in all 50 states. Manufacturing employs more than 12.3 million men and women, contributes $2.35 trillion to the U.S. economy annually and has the largest economic multiplier of any major sector and accounts for 63% of private-sector research and development. The 51�Թ��� is the powerful voice of the manufacturing community and the leading advocate for a policy agenda that helps manufacturers compete in the global economy and create jobs across the United States. For more information about the 51�Թ��� or to follow us on Twitter and Facebook, please visit www.nam.org

Washington, D.C. – Today, the leadership of the 51�Թ��� released the following statements on the need for action surrounding proposed bipartisan infrastructure legislation:

“Manufacturers have called for this type of bold bipartisan infrastructure investment for many years, across multiple congresses and administrations, so Congress should waste no time in sending the plan to President Biden’s desk,” urged 51�Թ��� President and CEO Jay Timmons. “We have watched America’s infrastructure deteriorate for too long as other nations invested in their own, aiming to outcompete the United States. Too often, it has cost us livelihoods and lives. This plan will bolster America’s competitiveness, strengthen the manufacturing industry and give American workers the foundation to build a new, post-pandemic world. This framework, which leaders in both parties and President Biden have embraced, confirms what manufacturers have said—that corporate tax increases are not the way to fund infrastructure. And with this legislation and its investments not just in roads and bridges but also waterways, the electric grid, advanced telecommunications and so much more, we can make history—and we can build that future and build to win.”

Trane Technologies Chairman and CEO and 51�Թ��� Board Chair Mike Lamach added, “All Americans will reap the benefits of this bold, bipartisan plan. For manufacturers, it means we’ll be able to better deliver for our customers. We’ll be better prepared to compete in the world. Our communities will be safer, our employees will be healthier, and our companies will be stronger. We stand behind this plan and want to see it move forward quickly in support of positive change for generations to come.”

“There’s no doubt that such strong investment in our nation’s infrastructure will move us forward in a profound way. As with any compromise agreement, there are concerns on both sides,” said Dow Chairman and CEO and 51�Թ��� Board Vice Chair Jim Fitterling. “Manufacturers and those who use everyday products are certainly concerned about the funding proposals related to new Superfund taxes, and we will work with lawmakers to address those—because we believe the infrastructure package should avoid targeting specific sectors, particularly when new taxes might inadvertently harm consumers and a critical sector of the manufacturing economy.”

BTE Technologies President and 51�Թ��� Small and Medium Manufacturers Group Chair Chuck Wetherington noted, “America’s small and medium-sized manufacturers know far too well the costs of navigating around clogged roadways and crumbling bridges. We know the costs of shipping delays and the stress and strain on our employees as they commute. We know what it’s like to worry about power failures and what it takes to install and operate the latest digital technologies on our shop floors. So, for small manufacturers, this bill offers a boost of confidence and optimism. It will allow us to focus more of our energy on what we do best: creating jobs and creating opportunity.”

“Whether you’re running a family business or focused on the business of your family, you don’t need anyone to tell you that America’s infrastructure needs help. After all, it’s estimated that outdated infrastructure costs families $3,300 in disposable income every year. Small manufacturers are dedicated to the success of our hometowns—and we can’t wait to see what we’ll be able to accomplish once this plan becomes law. Let’s make this plan a reality,” emphasized Ketchie President and Owner and 51�Թ��� SMM Vice Chair Courtney Silver.

-51�Թ���-

The 51�Թ��� is the largest manufacturing association in the United States, representing small and large manufacturers in every industrial sector and in all 50 states. Manufacturing employs more than 12.3 million men and women, contributes $2.35 trillion to the U.S. economy annually and has the largest economic multiplier of any major sector and accounts for 63% of private-sector research and development. The 51�Թ��� is the powerful voice of the manufacturing community and the leading advocate for a policy agenda that helps manufacturers compete in the global economy and create jobs across the United States. For more information about the 51�Թ��� or to follow us on Twitter and Facebook, please visit www.nam.org.

Washington, D.C. – The 51�Թ��� released its Manufacturers’ Outlook Survey for the second quarter of 2021. “Attracting and retaining a quality workforce” and “rising raw material costs” remain manufacturers’ biggest concerns for the second straight quarter. Despite those concerns, manufacturers predicted some of the highest expected growth rates in the survey’s history and the most positive outlook since the third quarter of 2018.

“Manufacturers see an incredible future on the horizon and are predicting growth numbers unheard of in the more than two-decade history of this survey,” said 51�Թ��� President and CEO Jay Timmons. “But yet, a dark cloud still hangs over the industry. Manufacturers face long-term workforce challenges, with a record-high 851,000 open manufacturing jobs right now and more than 4 million to be filled over the next decade. While a very serious concern, manufacturers are doing everything we can to meet this challenge. The 51�Թ��� and The Manufacturing Institute’s Creators Wanted campaign, including a first-of-its-kind mobile manufacturing experience, will cover thousands of miles in the second half of this year tackling the top two issues facing this critical workforce challenge: a skills gap and misperceptions about modern manufacturing.

“To keep this momentum going, elected leaders in Washington should advance policies that will enhance our competitiveness and strengthen our industry, starting with delivering bipartisan infrastructure investment. Failing to do so will rob generations to come of the opportunity to achieve their highest potential. Conversely, moving forward with proposed tax increases, as our studies have shown, would mean 1 million jobs lost in just the first two years. Anti-worker laws like the forced unionization PRO Act would upend our workplaces. Whether today’s manufacturing optimism is a passing moment or a new normal has a lot to do with the choices our elected leaders make.”

Survey highlights:

• 90.1% manufacturer optimism, highest since Q3 2018
• 3.7% expected growth in full-time employment, a record high
• 6.1% expected growth in sales over the next 12 months, a record high
• 5.9% expected growth in production over the next 12 months, a record high

Read the full Q2 2021 Manufacturers’ Outlook Survey results here.

Background on Creators Wanted:

The 51�Թ���, together with the MI, launched the Creators Wanted campaign, an unprecedented national effort to build the modern manufacturing workforce of tomorrow. By 2025, Creators Wanted aims to reduce the skills gap in the United States by 600,000, as well as increase the number of students enrolling in technical and vocational schools or reskilling programs by 25% and increase the positive perception of the industry among parents to 50% from 27%.

Creators Wanted is part of a  together with a , and it is part of sustained initiatives at  targeting youth, veterans, women and other underrepresented communities.

-51�Թ���-

The 51�Թ��� is the largest manufacturing association in the United States, representing small and large manufacturers in every industrial sector and in all 50 states. Manufacturing employs more than 12.3 million men and women, contributes $2.35 trillion to the U.S. economy annually and has the largest economic multiplier of any major sector and accounts for 63% of private-sector research and development. The 51�Թ��� is the powerful voice of the manufacturing community and the leading advocate for a policy agenda that helps manufacturers compete in the global economy and create jobs across the United States. For more information about the 51�Թ��� or to follow us on Twitter and Facebook, please visit www.nam.org.

The 51�Թ��� is joining with Meritas, a global legal alliance, to provide tailored, high-quality and affordable legal assistance to manufacturers across the country.

About the team: Meritas offers a network of 186 full-service, world-class law firms that have been vetted and approved by the organization. The firms are equipped to assist clients with issues from contracts and employment to environmental compliance and intellectual property.

How it works: If any members are facing legal issues, or simply want ongoing legal support for routine challenges, they can contact the 51�Թ���’s Manufacturers’ Compliance Institute, which will work with Meritas to identify exactly the right kind of legal professionals who can help. Meritas firms will then provide 30 minutes of free time to connect with the 51�Թ��� member to figure out if a more formal engagement makes sense. 51�Թ��� members can even connect with firms in other countries to work through issues that might arise abroad.

• Vetted firms: Meritas’ approved firms have all undergone a stringent vetting process to ensure they meet high standards. Instead of having to search for a reputable lawyer on their own, 51�Թ��� members can trust that we will connect them with high-quality professionals who can meet their needs.
• Local knowledge: The Meritas network includes more than 7,500 lawyers serving 253 markets in the United States and around the world. This partnership will help manufacturers find assistance and representation from firms that have legal expertise in the relevant region, ensuring they have the best possible information as they move forward.
• Affordable rates: Meritas firms provide high-value services at competitive rates for small businesses and large companies alike. For small and medium-sized manufacturers, Meritas makes legal counsel accessible, helping companies avoid common pitfalls and overcome complex challenges. For larger companies, it delivers strong support at a lower price point than more expensive firms, helping to ensure competitiveness and a strong bottom line.

Why it matters: Finding high-quality, affordable legal counsel with relevant knowledge is extremely challenging. The 51�Թ���’s partnership with Meritas makes that process simpler, saving you time and money and strengthening your operations.

The last word: “The 51�Թ���’s partnership with Meritas gives manufacturers around the country a clear line into an outstanding network of legal assistance,” said 51�Թ��� Vice President of Legal and Deputy General Counsel Patrick Hedren. “Whether you’re a small firm trying to avoid common legal challenges, a large company trying get more out of your legal team or an expanding manufacturer trying to navigate a new state or a new country, this partnership provides indispensable value and essential support.”

As India struggles with COVID-19, manufacturers across the United States have stepped up to offer assistance and material aid.

The situation: India is grappling with a dangerous and extremely transmissible form of COVID-19, even as the country has struggled to inoculate large swaths of its population. As a result, hospitals across the country are straining to fulfill critical needs, and the situation has become dire.

The support: Many manufacturers have announced that they will provide critical assistance to response efforts in India, including the following:

• donated four mobile oxygen trucks, working with the Indian Red Cross to get them to Delhi.
• donated $2.7 million to provide urgent medical resources and health care infrastructure, working with United Way Mumbai.
• sent $70 million worth of COVID-19 treatment medicines directly to India/Indian government to help fight the disease.
• donated 400,000 tablets of key medicine used to treat severe COVID-19 patients—and made new voluntary agreements to ramp up local manufacturing and distribution in India.
• donated $1 million to India to fight COVID-19.
• is donating critical supplies to India and has donated $4 million to help nonprofit organizations reach underserved communities get COVID-19 vaccines.
• is importing 1 million Low Dead Space (LDS) syringes, which minimize the amount of drug left in the syringes after an injection.
• created a $10 million emergency assistance package for India to support the country’s response to the recent surge in COVID-19 cases.
• is donating $100,000 to the U.S. India Friendship Alliance to help the organization provide 250 oxygen concentrators to India’s hospitals and medical facilities.

In related news, the United States will donate 500 million doses of Pfizer’s COVID-19 vaccine to the world, according to (subscription). The donations will be distributed this year and over the first half of next year to 92 lower-income countries and the African Union, via the COVAX vaccine program spearheaded by the World Health Organization and the Global Alliance for Vaccines and Immunization. The White House has also pledged additional direct aid to India, which is detailed .

• The 51�Թ��� has these efforts to accelerate vaccinations in India and the rest of the world, calling them a “powerful, effective way to improve vaccine access,” while preserving critical IP protections that made that innovation possible.

What we’re saying: “Manufacturers are deeply committed to the fight against COVID-19 in our communities, including here in the United States, in India and around the world,” said 51�Թ��� Director of International Business Policy Ryan Ong. “The 51�Թ��� is working directly with members and with partners like Good360 and SBP to provide critical relief where it is mostly badly needed and to help us all respond and recover from COVID-19 as we work toward a better post-pandemic world.”

Washington – Today, Jay Timmons, President and CEO of the 51�Թ���, Joshua Bolten, President & CEO of Business Roundtable, and Suzanne Clark, President and CEO of the U.S. Chamber of Commerce, issued the following statement:

“There is a clear path forward for bipartisan agreement on meaningful infrastructure legislation. We urge Congress and the Administration to seize this opportunity – one that has eluded policymakers for years – to enact significant investment and durable reforms that would strengthen the economic recovery and create the conditions for high-paying jobs over the long-term.

“Our organizations are united in the belief that a major investment in physical infrastructure can, and should, be financed in a manner that will help grow our economy and enable U.S. businesses to compete globally as we emerge from the pandemic. Specifically, instead of tax increases that would harm American businesses and workers, Congress can fund these critical infrastructure investments with a combination of public-private partnerships, user fees, and reallocated unused federal appropriations, among others. We also believe that public debt and bonding authority is an appropriate and logical funding source for capital projects with a multi-decade useful life span.

“A bipartisan deal is within reach, and at a time when our competitiveness around the globe is at stake. Congress and the Administration should continue bipartisan negotiations and pursue a regular order process. Now is the time to do the right thing for the country – not fall further behind.”

-51�Թ���-

The 51�Թ��� is the largest manufacturing association in the United States, representing small and large manufacturers in every industrial sector and in all 50 states. Manufacturing employs more than 12.3 million men and women, contributes $2.35 trillion to the U.S. economy annually and has the largest economic multiplier of any major sector and accounts for 63% of private-sector research and development. The 51�Թ��� is the powerful voice of the manufacturing community and the leading advocate for a policy agenda that helps manufacturers compete in the global economy and create jobs across the United States. For more information about the 51�Թ��� or to follow us on Twitter and Facebook, please visit www.nam.org.

Across the country, manufacturers are deeply involved in efforts to improve their climate stewardship and take action on a wide range of environmental, social and governance (ESG) issues. Manufacturers are leaders in everything from combatting climate change to in the workforce—and in ensuring that investors understand everything that goes into this critical work.

Recently, the Securities and Exchange Commission began considering a disclosure framework that could require companies to provide standardized information on their climate and ESG commitments. The agency has opened a comment period to receive public input on what the framework could include, and the 51�Թ��� is making sure that manufacturers’ voices are heard.

51�Թ��� Senior Director of Tax and Domestic Economic Policy Charles Crain recently spoke to us about this issue, describing manufacturers’ priorities and concerns. Here’s what you need to know.

The challenge: Many companies already voluntarily disclose a great deal of information about their climate and ESG efforts—both because they are proud of the work they do, and because they believe it’s important for investors to have all the information available, Crain says. However, a one-size-fits-all SEC mandate could create more problems than it solves by imposing costly or overly broad requirements that do not provide useful information to shareholders.

Our move: This week, the 51�Թ��� the manufacturing industry’s perspective for the SEC, including a list of principles that should guide the agency’s decision-making. Those principles include the following:

• Materiality: The 51�Թ��� believes that companies should be required to disclose information only if it is material to their business—that is, company-specific, relevant, useful information that would change a reasonable investor’s view of a company.
• Flexibility: Different items are material for different companies. Disclosures shouldn’t be one-size-fits all, but should instead include the kind of company-specific information that will reflect the diversity of risks and opportunities that businesses face and thus be useful to investors.
• Clarity and comparability: The current lack of standardization can create costs and uncertainty for both companies and investors. Within a flexible, materiality-driven framework, the SEC can enhance the clarity and comparability of climate and ESG information disclosed by businesses.
• Limiting company costs and liability: New SEC mandates shouldn’t overburden companies with high costs or a strict liability burden—both of which could result in limited or boilerplate reporting that isn’t useful to investors. Many of companies’ climate and ESG goals are aspirational and rely on evolving reporting methodologies, and the SEC shouldn’t disincentivize aggressive goal-setting on these issues.
• Appropriate scope and reasonable timelines: The data the SEC is describing isn’t just sitting on the shelf. In order to disclose climate and ESG information under a new framework, many companies could have to build out data collection infrastructure, go deep into the supply chain, and get information through standardized methodologies that may not currently exist. This process will be time-consuming and difficult, and the SEC will need to tailor any requirements accordingly and give companies time to adapt.
• Don’t reinvent the wheel: Many companies are already disclosing climate and ESG information based on existing methodologies, and there are plenty of third-party standards for reporting this data. Rather than starting from scratch, any SEC framework should align with existing practices that many companies are already using.

Next steps: The SEC will consider the 51�Թ���’s recommendations, along with other feedback, as it works toward a potential rule proposal—and the 51�Թ��� will continue to engage with the SEC throughout the process.