Passage of the CLARITY Act would not make the measure immediately effective because the SEC and CFTC (U.S. derivatives regulator) would still need to draft implementing rules, a process that would take at least several months, former SEC staff member Anne Kelley said on Aug. 14. She said the SEC's upcoming public meeting on a tokenization innovation exemption is only the first step in proposed rulemaking, which must still go through public comment and other procedures. Kelley added that binding final rules must comply with the U.S. Administrative Procedure Act, or APA (U.S. federal rulemaking law), so they can withstand judicial review. If the CLARITY Act passes while rulemaking is underway, regulators would not need to restart the process and could instead revise an existing proposal through a supplemental notice of proposed rulemaking, or SNPRM (updated draft rule notice), and continue. As a comparison, she cited the GENIUS Act, saying it was passed a year ago but has still not been fully implemented, in part because supporting rules take time to complete.