Government Category: Comments & Letters to Regulators

Letters to Regulators: IOSCO Should Explicitly Acknowledge That Environmental and Social Integrity Are Critical Components of the Market Integrity of Carbon Credits

Americans for Financial Reform Education Fund (AFREF) submitted a comment letter on The Board of the International Organization of Securities Commissions (IOSCO)’s Consultation Report outlining a proposed set of Good Practices to promote the integrity and orderly functioning of Voluntary Carbon Markets (VCMs). IOSCO has appropriately developed a proposed set of 21 Good Practices in

Letters to the Regulators: Letter Urging The SEC to Repropose the Stock Buybacks Disclosure Rule

Americans for Financial Reform Education Fund (AFREF) led a letter with 13 additional signatories urging the SEC to repropose the stock buybacks disclosure rule to provide investors with information about this widespread yet opaque practice. This important rule was struck down by the Fifth Circuit Court of Appeals following a challenge by the Chamber of Commerce.

Letters to the Regulators: Letter Urging The SEC to Require Human Capital Management Disclosures

Americans for Financial Reform Education Fund (AFREF) led a letter with 16 additional signatories urging the SEC to propose a rule requiring public companies to make human capital management disclosures as soon as possible. Investors are in desperate need of consistent, comparable, and decision-useful workforce information.

Letters to the Regulators: Letter in Support of Developing a Financial Inclusion Strategy

Americans for Financial Reform Education Fund (AFREF) sent a letter to the Treasury Department outlining principles, scope, and direction for the department’s development of a financial inclusion strategy. Developing a financial inclusion strategy is long-overdue and a necessary step to understand and begin to address the contributions of inequitable access to financial products and services for disadvantaged communities to the persistent racial economic inequality in the United States.

Letters to Regulators: CFTC Should Finalize Guidance and Continue Close Monitoring of Risks of Voluntary Carbon Credit Derivatives Contracts

Americans for Financial Reform Education Fund (AFREF) submitted a comment letter to the Commodity Futures Trading Commission (“CFTC”) on its proposed guidance for designated contract markets (“DCMs”) on commodity characteristics that should be considered in terms and conditions for the listing of voluntary carbon credit (“VCC”) derivative contracts. The letter recommends that first, the CFTC

Letters to the Regulators: Letter in Opposition to the CFTC’s Proposed Rulemaking and its Dangerous Precedent

Americans for Financial Reform Education Fund and Consumer Federation of America, Food & Water Watch, Institute for Agriculture and Trade Policy, and Public Citizen sent a letter sharing their grave concerns with the justification and potentially calamitous precedent contained in the Commodity Futures Trading Commission’s (CFTC’s) proposed rulemaking for the Investment of Customer Funds by

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