View or download a PDF of the letter here.
AFREF sent a letter to the Securities and Exchange Commission supporting its proposal to treat index providers as investment advisers given the many traits of index providers that resemble investment advice.
Such proposals are necessary as index funds have grown to become a multi-trillion dollar industry but one whose decisions to include or exclude issuers from the indices, and which many fund managers must closely follow, remain opaque and feature a number of conflicts-of-interest.