Tag Archives: investor protection

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Letters to Regulators: Letter to the SEC on Corporate Governance Implications of Securities Lending

AFREF sent a letter commenting on the Security and Exchange Commission’s proposed rule to increase the transparency and efficiency of the securities lending market. Having already commented in support of the proposed rule, we submitted an additional comment to address its corporate governance implications. The securities lending market—as it pertains to equity shares—has important corporate governance implications, as investors cannot vote shares on loan. In our comment, we recommend the Commission enhance the proposed rule’s public disclosures to give investors the tools they need to ensure the securities lending practices of asset managers and retail brokers do not interfere with investors’ role in corporate governance.

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Letters to Regulators: Comment Letter Supporting the SEC’s Proposal to Expand Position Disclosure Requirements via Form PF

AFREF sent a comment to the Securities and Exchange Commission supporting the agency’s proposal to expand position disclosure requirements (via Form PF) for both hedge funds and private equity funds. Many of the disclosure exemptions were formed when both types of funds were fractions of the size they are today and would give the SEC and by extension, the Financial Stability Oversight Council (FSOC) critical information to prevent the uncertainty and threats to financial stability that we saw with Long Term Capital Management in 1999 as well as the financial crises of 2008 and March 2020.

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Letters to Regulators: Letter Commenting on the SEC’s Proposed Rule on Executive Compensation

AFREF sent a letter commenting on the Security and Exchange Commission’s proposed rule to implement Section 953(a) of the Dodd-Frank Wall Street Reform and Consumer Protection Act, relating to executive compensation for financial performance.  The letter welcomes the SEC’s implementation of this important provision and makes recommendations to minimize executives’ incentives to focus on short-term shareholder returns at the expense of longer-term investments that contribute to equitable and sustainable economic growth over time.