It would be Crazy! If in the 11th hour they push it back 3-6 months.
Totally crazy, which is why I'm pretty sure there's no chance they'll do it. The SEC has said nothing. FINRA has said nothing. OTC Markets has said nothing. The BDA has said nothing. SIFMA has said nothing.
Were they to decide to require all bond issues except for munis to file Forms 211 with FINRA, chaos would ensue. There're just too many issuers.