AFREF, the AFL-CIO, Communications Workers of America, the Interfaith Center on Corporate Responsibility, and Public Citizen submitted a comment letter in support of the SEC’s proposal to modernize beneficial ownership reporting in response to a new memorandum by the Division of Economic and Risk Analysis. The memorandum lays bare the fact that the outdated, 10-day 13D filing deadline unfairly distorts the market by having a prolonged period of unnecessary information asymmetry.
