Category Archives: Letters to Regulators

SEC Building

Letters to Regulators: Letter to the SEC in Support of its Proposal on Shareholder Proposals

AFREF and allies submitted a comment letter to the Securities and Exchange Commission in support of its proposal to update certain substantive bases for exclusion of shareholder proposals. Shareholder proposals are an important part of our corporate governance system, and in the letter, we encourage the Commission to ensure the full range of benefits of shareholder proposals are taken into consideration when finalizing the rule, including shareholder proposals’ role in identifying, raising awareness, and addressing both company-level and systemic risks.

SEC Building

Letters to Regulators: Letter to the SEC in Response to Request for Comment on Certain Information Providers Acting as Investment Advisors

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.