Category Archives: Letters to Regulators

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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. 

Letter to Regulators: Letter to the Federal Reserve on the Community Reinvestment Act Proposed Rulemaking

Americans for Financial Reform Education Fund, along with 25 undersigned organizations, is pleased to submit comments responding to the Joint Notice of Public Rulemaking (NPR) from the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively “the agencies”) regarding changes to the Community Reinvestment Act of 1977 (CRA).

Photo by Tom Rumble on Unsplash

Letters to Regulators: Community Reinvestment Act Regulation Update

Americans for Financial Reform Education Fund (AFREF) and partners submitted comments to the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation on their proposed revision to the regulations that implement the Community Reinvestment

SEC Building

Letters to Regulators: Letter to the SEC Commenting on Listing Standards for Recovery of Erroneously Awarded Compensation

AFREF submitted a comment letter in support of the SEC’s proposed rule on clawbacks of erroneously-awarded executive compensation. Once finalized, the rule will signify the long-overdue implementation of a Dodd-Frank provision that sought to improve incentives for honest and transparent corporate governance by creating a mechanism for the clawing back of compensation awarded based on inaccurate financial statements. AFREF submitted a comment in support of the proposed rule in 2015, and submitted this additional comment to answer questions raised by the Commission upon reopening the comment period