Tag Archives: SEC

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Letters to Regulators: Letter to the SEC Commenting on Listing Standards for Recovery of Erroneously Awarded 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

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Letters to Regulators: Follow Up Comment to the SEC on Private Funds

AFREF sent a Follow Up Comment to the Securities and Exchange Commission expressing support for its proposals that would require private fund advisers to provide their investors with greater and more detailed information around the fees, expenses, returns, and bilateral investment relations (via side letters). We echo many of the comments the SEC has since received since its initial comment period and reflect how current market conditions make the Commission’s proposals especially a priority given the variation in the reporting and valuation of private market assets. 

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Letters to Regulators: Comment to the SEC on SPACs

AFREF sent a letter to the Securities and Exchange Commission expressing its support for its many proposals that would amend the definition of a “blank check company” to include the current and any future iterations of Special Purpose Acquisition Companies (SPACs). Such proposals would impose greater liability on many involved in the creation and distribution of SPACs and provide investors with greater transparency into the forward looking projections that the issuers of SPACs have been misleadingly overly optimistic with.

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Letter to Regulators: Letter Commenting on the SEC’s Proposal on Money Market Reforms

AFREF sent a letter to the Securities and Exchange Commission supporting its proposals to reform Money Market Mutual Funds to better protect investors and the financial system. Money Market Mutual Funds have now been bailed out by policymakers twice in the last 12 years and benefit from paying higher interest rates above bank deposits without being subject to the same investor protection and safeguards as them.

A pair of hands writing on paper with a pen

Letters to Regulators: Modernization of Beneficial Ownership Reporting

AFREF sent a comment to the Securities and Exchange Commission (SEC) supporting the SEC’s proposals to modernize the reporting of beneficial ownership by including cash-settled derivatives in large position reports over Schedules 13D and 13G. We also urge the SEC to clarify its definition of who should constitute a “group” under the proposal as it should only apply to the sharing of material nonpublic information related to not yet disclosed large positions instead of efforts to improve the long-term corporate governance of companies.