April 2031 sunset is the actual deadline — staff guidance is one chair away from joining SAB 121 in the bin, and SAB 122 rescinded that within weeks of the admin change. DEF rallying 30+ co-signers because Atkins won't be there forever, and a durable broker-dealer carveout needs APA notice-and-comment rulemaking, not a Division statement. Post-Loper Bright that path is brutal but it's the only one that survives political turnover.

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