Tag Archives: SEC

Letter to Regulators: Silicon Valley Bank Failure Demonstrates the Need to Implement Key Executive Pay Rule, Dodd-Frank Section 956

AFREF, the Institute for Policy Studies, Global Economy Project, and Public Citizen led a letter with 22 additional signatories to the agencies tasked with implementing section 956 of Dodd-Frank. That section tasked six agencies with promulgating regulations to prevent incentive-based executive compensation that encourages “inappropriate risk” by May 2011.  Almost 12 years later, we don’t have a final rule. The letter was sent to regulators ahead of congressional hearings that will examine recent bank failures.

Letters to Regulators: Letter From 29 Signers to the SEC on Passing Strong Final Rules on Private Fund Advisers to Protect Investors and the Financial System

AFREF led a letter with 29 signers to the Securities and Exchange Commission reiterating the important need to pass a strong set of final rules related to requiring private fund advisers to disclose a complete breakdown of fees/expenses, assumptions used to calculate returns, and the existence of side letters to investors.

The letter is also urging the SEC to finalize a strong set of rules related to requiring private fund advisers over a certain size to report more detailed information about their holdings confidentially to the SEC so that the SEC and other financial regulatory agencies have much greater insight into the risks in the $21 trillion private fund space where there is currently little visibility in order to better safeguard the financial system.

SEC Building

Letters to Regulators: Letter to the SEC on Standards for Covered Clearing Agencies for U.S. Treasury Securities and Application of the Broker-Dealer Customer Protection Rule With Respect to U.S. Treasury Securities Fund Advisers

AFREF submitted a comment to the Securities and Exchange Commission (SEC) on December 27th supporting its proposals that would centrally clear the $27 trillion U.S. Treasury market, one of the largest and most systemically important markets in the world. 

Shockingly, despite the Treasury market’s importance, no one regulator has complete visibility into this market and the SEC’s proposals move closer to implementing the Inter-Agency Working Group on Treasury Market Surveillance’s (IAWG) recommendations to give regulators such as the SEC and the Financial Stability Oversight Council (FSOC) greater visibility and oversight.  

SEC Building

Letters to Regulators: Letter to the SEC in Support of its Proposal on Shareholder Proposals

AFREF and allies submitted a comment letter to the Securities and Exchange Commission in support of its proposal to update certain substantive bases for exclusion of shareholder proposals. Shareholder proposals are an important part of our corporate governance system, and in the letter, we encourage the Commission to ensure the full range of benefits of shareholder proposals are taken into consideration when finalizing the rule, including shareholder proposals’ role in identifying, raising awareness, and addressing both company-level and systemic risks.

SEC Building

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.