View or download a PDF of the letter here.
Americans for Financial Reform Education Fund submitted a comment letter opposing the SEC’s sweeping Registered Offering Reform proposal, which would expand access to short-form and shelf registration while weakening longstanding public float, seasoning, disclosure, and state-law safeguards. The proposal would expose investors to greater risks from smaller and less-seasoned issuers, is based on an inadequate economic analysis, and would improperly preempt state registration requirements that provide important protections for retail investors.