Category Archives: Education Fund

Letters to the Regulators: Letter to PCAOB Supporting Proposed Audit Standards to Report Noncompliance with Laws and Regulations, Including Climate Regulations

AFREF joined Public Citizen in a comment urging PCAOB to strengthen and swiftly finalize its proposed updated audit standards around reporting noncompliance with laws and regulations and identifying risks of material misstatement in financial statements. Climate-related accounting fraud is on the rise, and many companies are misrepresenting their financial position by underestimating their asset retirement obligations and environmental liabilities, and failing to substantiate public climate commitments in their financial statements and SEC filings. 

The proposed regulatory updates from PCAOB would strengthen auditors’ responsibilities to identify and report these types of misstatements and fraud and provide a significant benefit to investors by catching costly noncompliance issues early before they harm financial performance, and to the public by deterring corporate law-breaking and noncompliance.

Letters to Congress: Letter Opposing Anti-ESG Bills

Americans for Financial Reform sent a letter to the House Financial Services Committee opposing bills that undermine shareholders’ ability to make sound financial decisions and hold corporations accountable. In our letter, we provide an overview of the bills noticed during the various ESG hearings and briefly discuss why we oppose them.

Letters to the Regulators: Letter to the SEC Supporting the Prohibition of Conflicts of Interests in Securitization

Americans for Financial Reform Education Fund submitted a comment to the Securities and Exchange Commission (SEC) supporting its proposal to prohibit conflicts of interest in securitizations. Such conflicts were at the heart of the Great Financial Crisis of 2008 leading to trillions of dollars in losses across the financial system and irreparable harm to millions of homeowners. Now, with the growth in securitizations such as those backed by commercial real estate and other assets, the SEC’s proposals can ensure that similar practices do not happen again at the harm of investors and others.

lawyer signing a document Photo by Helloquence on Unsplash

Letters to Regulators: Comment on OIRA Cost Benefit Analysis Guidance

AFREF submitted comments to the Office of Information and Regulatory Affairs on its proposal to modernize the regulatory process to better account for racial and economic inequality, climate change, and other factors within economic analysis; and improve transparency and empower and benefit members of marginalized communities through the regulatory process.

Letters to Regulators: Letter to CMS on Proposed Rule on Ownership of Nursing Facilities

AFREF submitted a comment to the Centers for Medicare and Medicaid Services (CMS) on their proposed rule to require the disclosure of important information regarding the ownership and control of nursing facilities, including when an owning or managing entity is a private equity (PE) company or a Real Estate Investment Trust (REIT).

Private equity and healthcare are incompatible and AFREF states in the letter that the current lack of transparency in ownership of facilities exacerbates the problem and shields owners and investors from accountability for the performance of the businesses they own and welcomes the disclosure rule.