AFREF submitted and joined coalition comment letters in response to the Securities and Exchange Commission (SEC)’s proposed rule on climate disclosure. The coalition letters focused on Environmental Justice, Community Impacts, and Indigenous rights.
AFREF sent a Follow Up Comment to the Securities and Exchange Commission expressing support for its proposals that would require private fund advisers to provide their investors with greater and more detailed information around the fees, expenses, returns, and bilateral investment relations (via side letters). We echo many of the comments the SEC has since received since its initial comment period and reflect how current market conditions make the Commission’s proposals especially a priority given the variation in the reporting and valuation of private market assets.
AFREF sent a letter to the Securities and Exchange Commission expressing its support for its many proposals that would amend the definition of a “blank check company” to include the current and any future iterations of Special Purpose Acquisition Companies (SPACs). Such proposals would impose greater liability on many involved in the creation and distribution of SPACs and provide investors with greater transparency into the forward looking projections that the issuers of SPACs have been misleadingly overly optimistic with.
AFREF and Public Citizen sent a letter to PCAOB in response to their request for comment on their Interim Analysis of Estimates and Specialists Audit Requirements.
AFREF submitted two comments to the Federal Deposit Insurance Corporation in response to their request for comment on “Statement of Principles for Climate- Related Financial Risk Management for Large Financial Institutions.” The first comment was a joint letter signed by 13 partners regarding the fair
AFREF joined a letter to HUD urging them to adopt enhancements to the FHA COVID-19 waterfall to address the impact of rising interest rates.
AFREF joined a letter in support of HUD’s proposed amendment to 24 C.F.R. § 203.616, which would increase the maximum payment term of a loan modification from 360 months to 480 months.
AFREF and Demand Progress submitted a letter in response to the Federal Reserve’s Request for Information on a Central Bank Digital Currency (CBDC). In the submission, we urge the Fed to consider privacy and fraud protection, and also point to other alternatives to CBDC the Fed could pursue to promote broader financial inclusion.
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.
AFREF joined Consumer Federation of America and Better Markets in a comment letter in response to FINRA’s request for comment on complex products calling for protections that extend beyond greater disclosures for retail investors who are vulnerable to losing significant amount of money unexpectedly on a number of complex and risky products.