President Biden’s and Congress’s efforts to begin to hold the executives of Silicon Valley Branch accountable are important to rein in the reckless and imprudent practices of senior bank executives, who have gamed our financial system and hurt communities in the process. True accountability includes executives forfeiting enormous bonuses, while their bank is on the brink of failure.
AFREF and the Institute for Policy Studies, Global Economy Project led a comment letter to the Office of Management and Budget (OMB) about its uniform guidance, which sets the boundaries around the types of strings states and localities are allowed to attach when they disburse federal funds. This comment letter argues state and local governments should be allowed to give preferential treatment to bidders that commit to make productive investments in their companies and refrain from stock buybacks and excessive executive 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
AFREF sent a letter commenting on the Security and Exchange Commission’s proposed rule to increase the transparency and efficiency of the securities lending market. Having already commented in support of the proposed rule, we submitted an additional comment to address its corporate governance implications. The securities lending market—as it pertains to equity shares—has important corporate governance implications, as investors cannot vote shares on loan. In our comment, we recommend the Commission enhance the proposed rule’s public disclosures to give investors the tools they need to ensure the securities lending practices of asset managers and retail brokers do not interfere with investors’ role in corporate governance.
AFREF sent a letter commenting on the Security and Exchange Commission’s proposed rule to implement Section 953(a) of the Dodd-Frank Wall Street Reform and Consumer Protection Act, relating to executive compensation for financial performance. The letter welcomes the SEC’s implementation of this important provision and makes recommendations to minimize executives’ incentives to focus on short-term shareholder returns at the expense of longer-term investments that contribute to equitable and sustainable economic growth over time.
Lordstown Motors was supposed to be a promising electric vehicle startup backed by General Motors that would help revolutionize low-emissions vehicles while also revitalizing America’s “Rust Belt”. Instead, many of its promises, exploiting the loopholes in the SPAC model, were soon found to be untrue, reiterating the important changes that need to be made to the business model of companies taken public through SPACs.
AFR opposed twelve bills that would leave investors more vulnerable to harm and abuse, and make the nation’s capital markets less safe, and supported five of the measures that would improve disclosures or investor protections.
AFR sent a comment letter to the Federal Reserve Board urging them to modify proposed rules that would reduce accountability for bank Boards of Directors, and also to examine further changes that would expand such accountability AFR Response to Proposed Guidance On Boards of Directors