The Securities and Exchange Commission, charged with protecting investors and overseeing the securities markets, has been busy since January, issuing 16 proposed rules, the most since 2011 when the agency issued 17 proposals in the wake of the Dodd-Frank Act.

Are 16 SEC rules proposals in four months too many?

The answer is yes, according to the Securities Industry and Financial Markets Association, a trade group that represents the biggest broker-dealers on Wall Street and nationwide.

Sifma and 24 other financial services trade groups wrote SEC Chair Gary Gensler with this complaint earlier in April.

“Some proposals address areas in need of immediate action, but many others not necessarily so,” said Kenneth E. Bentsen Jr., the president and CEO of Sifma, in an op-ed in The Hill last week.

“Worse, the SEC has broken with precedent by giving the public fewer than 60 days to provide comments and cost-benefit analysis on most new rules,” Bentsen added.

A Bloomberg story called it the SEC’s most aggressive rule-making initiative in history.

Last fall, the SEC released its list of upcoming new rules, citing 54 separate items that required comment. In just the past five months, the agency issued 24 proposals “making an array of changes to complicated securities laws and complex financial markets. Just 12 such proposals total roughly 3,500 pages of text and ask 2,200 separate questions,” Bentsen noted.

In one week, Wall Street firms and their trade groups were tasked with commenting on three SEC proposals—on cybersecurity issues for advisors, on the requirements for reporting on the beneficial ownership of firms, and on the settlement dates for broker-dealer transactions. The Investment Adviser Association (IAA) sent the SEC three comment letters on the three complex proposals in one day—April 11.

IAA’s President Karen Barr said in an interview that IAA’s general counsel and attorneys “worked through the night” to provide meaningful comment on regulatory proposals critical to registered investment advisors and their clients.

IAA spokeswoman Meredith Wise took to email to make all three comment letters available to reporters simultaneously.

Federal guidance states that the public should have at least 60 days to comment on a rule after its publication in the Federal Register, Bentsen argued.

For particularly complex rules, the public commonly should have 90 days to comment, Bentsen argued.

“But of the SEC’s comment periods under the current Chair Gary Gensler, 37% have been 30 days, 11% have been 45 days, 7% have been 60 days, and none have been 90 days, he added.

In contrast, rules proposed by previous SEC chairs Mary Jo White and Jay Clayton gave the public 60-day comment periods at least 76% of the time, and 90 days at least 9% of the time.

The SEC did not immediately respond to a request for comment.

“Wall Street and its paid lobbyists always see bringing transparency to the financial system as an action that will overload the system,” quipped Richard Field, the director of the Institute for Financial Transparency, on Twitter.

But Bentsen argues, “Rushing through multiple expansive new rules simultaneously … could make it harder and more expensive for everyone to access the financing they need, and could have an adverse impact on the real economy in terms of output, employment, wages and prices, which would only compound the economic challenges and uncertainty we’re currently facing.”

Some 25 trade groups, including Sifma, the IAA, the American Council of Life Insurers and the U.S. Chamber of Commerce, sent Gensler a letter on April 5 stressing “the importance of appropriate length of comment periods.”

Regulators need the input of B-Ds, insurance companies and banks “that often have the necessary technical expertise to forecast” a potential rule’s consequences, identify where problems will arise and suggest alternatives, the trade groups wrote.

It’s also important for the SEC to give investors and other interested parties the time to respond in case they want “more, less or a different type of protection than the agency is proposing,” the associations added.