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 […]

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Letters to Regulators: Letter to the SEC on Stock Buybacks

AFREF led a letter with thirteen organizational signatories commenting in support of a rule proposed by the Securities and Exchange Commission that would significantly increase the transparency of stock buybacks.  A central component of the proposed rule is daily disclosures of stock buybacks.  (Current disclosure requirements are only quarterly.)  In the comment letter, we commend the SEC […]

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Letters to Regulators: Letter to the SEC Commenting on Reporting of Securities Loans Proposal

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 […]

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Letters to Regulators: Comment Letter in Response to the SEC’s Proposal on Swaps/Derivatives/13-F

AFREF sent a comment to the Securities and Exchange Commission calling for the agency to close long-running loopholes that have enable certain hedge funds to use swaps and derivatives to avoid disclosing large positions which in turn lead can unnecessary lead to coordinated attacks on companies and unnecessary volatility in the underlying prices of certain […]

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Letters to Regulators: Comment Letter Supporting the SEC’s Proposal to Expand Position Disclosure Requirements via Form PF

AFREF sent a comment to the Securities and Exchange Commission supporting the agency’s proposal to expand position disclosure requirements (via Form PF) for both hedge funds and private equity funds. Many of the disclosure exemptions were formed when both types of funds were fractions of the size they are today and would give the SEC and […]

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Letters to Regulators: Letter Commenting on the SEC’s Proposed Rule on Executive Compensation

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 […]

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Letters to Regulators: Letter to DOL Urging Modernization of Fiduciary Rule

AFREF and the Save Our Retirement Coalition sent a letter calling on the Department of Labor to expeditiously update and strengthen the rules governing retirement investment advice to help protect workers and retirees from harmful conflicts of interest. The post Letters to Regulators: Letter to DOL Urging Modernization of Fiduciary Rule appeared first on Americans […]

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Letters to Regulators: Comment Letter on DOJ’s Consideration of Whether to Strengthen the 1995 Bank Merger Competitive Review

AFREF sent a letter commenting on the U.S. Department of Justice’s consideration of whether to strengthen the 1995 Bank Merger Competitive Review. The post Letters to Regulators: Comment Letter on DOJ’s Consideration of Whether to Strengthen the 1995 Bank Merger Competitive Review appeared first on Americans for Financial Reform.

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