Americans for Financial Reform

Government Category: Advocacy Documents

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. 

Letters to Regulators: Environmental, Social, and Governance (ESG) Names and Disclosures for Investment Funds

Americans for Financial Reform Education Fund (AFREF) submitted comments to the Securities and Exchange Commission (SEC) on their proposed rules regarding fund names and required Environmental, Social, and Governance (ESG) disclosures for investment funds and advisers. These proposed rules would prevent the use of misleading fund names and require investment funds with sustainability-themed names like