Committee Staff Releases Update on Monetary Sanctions Imposed by U.S. Enforcement Agencies (for Calendar Year 2021)

On August 31, 2022, the Committee staff released an update on the monetary sanctions imposed during calendar year 2021 by public enforcement agencies with oversight of the U.S. financial system.This statement updates the staff report on “Rationalizing Enforcement in the U.S. Financial System” released in June 2018, which reviewed enforcement actions brought and monetary sanctions […]

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Committee Submits Response to SEC’s Request for Comment on Index Providers

On August 15, 2022, the Committee submitted a letter in response to a request for comment from the Securities and Exchange Commission (“SEC”) on “Certain Information Providers Acting As Investment Advisers” (the “Request for Comment”). The Request for Comment seeks input on the extent to which financial index providers, model portfolio providers, and pricing services […]

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Committee Submits Comment Letter on the SEC’s ESG Fund Disclosure Proposal

On August 15, 2022, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposal on enhanced disclosure requirements with respect to environmental, social, and governance  (“ESG”) investment practices by registered investment companies and investment advisers. The Committee supports the SEC’s goals of “promot[ing] consistent, comparable, reliable—and therefore decision […]

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The Unprecedented Incidence of Recent Rulemakings by the SEC

On July 15, 2022, the Committee released its first in a series of visual diagrams designed to track the unprecedented scale and complexity of recent rulemaking activity by the U.S. Securities & Exchange Commission (the “SEC”).   The Committee’s “Rulemaking Incidence Diagram” depicts proposed and final SEC rulemaking actions taken under SEC Chairman Gary Gensler, […]

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Committee Submits Comment Letter on the SEC’s Proposal on Climate Disclosure

On June 16, 2022, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposed rule to require public companies to provide specified climate-related information in their registration statements and annual reports (the “Proposed Rule”). The Committee agrees with the Proposed Rule that it is important to “provide consistent, […]

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Committee Submits Comment Letter on the SEC’s Proposal on SPACs

On June 13, 2022, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposed rule on special purpose acquisition companies (“SPACs”), shell companies, and projections (the “Proposed Rule”). As set forth throughout the letter, the Committee’s review of empirical data on SPACs and de-SPACs finds that SPACs play […]

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Committee Submits Comment Letter on the Fed’s CBDC Consultation Paper

On May 20, 2022, the Committee submitted a comment letter to the Federal Reserve Board (the “Fed”) concerning its recent consultation paper, “Money and Payments: The U.S. Dollar in the Age of Digital Transformation,” which invites public discussion of the creation of a central bank digital currency (a “CBDC”). The Committee finds that the principal […]

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Committee Hosts Virtual Roundtable on IPOs and the Rise of SPACs

On April 27, 2022, the Committee hosted a Virtual Roundtable on “The Future of Going Public and Expanding Investor Opportunities: A Comparative Discussion on IPOs and the Rise of SPACs.” The roundtable vegan with Keynote Remarks from Commissioner Caroline Crenshaw of the U.S. Securities & Exchange Commission, followed by a panel discussion among subject matter […]

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Committee Submits Comment Letter on the SEC’s Private Funds Proposal

On April 25, 2022, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposed rule on private fund advisers (the “Proposed Rule”). The Proposed Rule includes a series of new rules and amendments under the Investment Advisers Act of 1940, as amended, applicable to investment advisers to private […]

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Committee Submits Comment Letter on the SEC’s Money Market Fund Proposal

On April 11, 2022, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposed rule on money market fund reforms. The Proposed Rule would make extensive changes to the rules governing money market funds (“MMFs”) under the Investment Company Act of 1940 (the “Act”), including by: (i) increasing […]

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