Category Archives: Letters to Regulators

a melting glacier

Letters to Regulators: Comment Letter on DOL Climate Risk RFI

AFREF and 17 partners submitted comments to the Department of Labor on its request for information on climate risk to retirement plans and pensions, urging further integration of systemic risks like climate change, environmental, racial, and economic inequality into the administration of private retirement plans and pensions and the Federal Thrift Savings Plan.

SEC Building

Letter to Regulators: Letter Commenting on the SEC’s Proposal on Money Market Reforms

AFREF sent a letter to the Securities and Exchange Commission supporting its proposals to reform Money Market Mutual Funds to better protect investors and the financial system. Money Market Mutual Funds have now been bailed out by policymakers twice in the last 12 years and benefit from paying higher interest rates above bank deposits without being subject to the same investor protection and safeguards as them.

A pair of hands writing on paper with a pen

Letters to Regulators: Modernization of Beneficial Ownership Reporting

AFREF sent a comment to the Securities and Exchange Commission (SEC) supporting the SEC’s proposals to modernize the reporting of beneficial ownership by including cash-settled derivatives in large position reports over Schedules 13D and 13G. We also urge the SEC to clarify its definition of who should constitute a “group” under the proposal as it should only apply to the sharing of material nonpublic information related to not yet disclosed large positions instead of efforts to improve the long-term corporate governance of companies.

SEC Building

Letters to Regulators: Letter to the SEC on Stock Buybacks

AFREF led a letter with thirteen organizational signatories commenting in support of a rule proposed by the Securities and Exchange Commission that would significantly increase the transparency of stock buybacks.  A central component of the proposed rule is daily disclosures of stock buybacks.  (Current disclosure requirements are only quarterly.)  In the comment letter, we commend the SEC on the proposed rule and make recommendations to further strengthen protections against market manipulation and insider trading that we believe would improve long-term financial stability and growth.