Tag Archives: SEC

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AFR-CFA Comment Letter: Business Conduct Standards

The Securities and Exchange Commission has proposed business conduct rules for security-based swap dealers and major security-based participants that AFR and CFA have said will not be effective in ending abusive practices and do not do enough to bring transparency to this market. Of particular concern are serious shortcomings in the provisions designed to provide enhanced protections for special entities, such as municipalities and pension funds, shortcomings that all but guarantee the rules will not deliver the intended enhanced protections. In a comment letter filed with the SEC yesterday, AFR and CFA urged the agency to comprehensively revise the rules to address weaknesses in virtually every provision of the rules and make them at least as strong as those proposed earlier this year by the CFTC.

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AFR Supports 953(b) – Calls for Disclosure of Executive Compensation

AFR wrote a comment letter supporting the requirement in Section 953(b) of the Dodd-Frank Act that companies disclose to investors the ratio of CEO pay to the compensation of the typical employee at the company. Existing requirements mandate disclosure of top executive compensation only, encouraging companies to focus unduly on peer to peer comparisons when setting CEO pay. Disclosure of CEO-to-worker pay ratios will encourage Boards of Directors to also consider pay equity within firms, top-to-bottom and not just at the CEO level. This information will also be useful to investors who prioritize pay equity as part of their investment decision. Rep. Nan Hayworth (NY) has introduced a bill to repeal this section of Dodd-Frank.

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AFR Short Term Borrowing

PDF version available here February 22nd, 2011 Mary Schapiro Chairman Securities and Exchange Commission 100 F Street, NE Washington, DC   20549 Cc: Luis Aguilar, Commissioner Cc: Kathleen Casey, Commissioner Cc: Troy Paredes, Commissioner Cc: Elisse Walter, Commissioner Cc: Elizabeth M. Murphy, Secretary Re: File No.