Letter to the SEC: Mutual Fund Disclosure Modernization

Download Public Comment Summary ​In her December 15, 2020 letter to the Securities and Exchange Commission (SEC), Barbara Roper, representing the Consumer Federation of America, addresses the SEC’s proposal to modernize mutual fund disclosures. While expressing general support for creating tailored shareholder reports that emphasize key information for retail investors, Roper opposes industry suggestions to […]

Letter to the SEC: Proposed Private Offering Expansion Threatens Investor Protections and Market Transparency

Download Public Comment   Summary In an October 1, 2019, letter to the Securities and Exchange Commission (SEC), Barbara Roper, Director of Investor Protection at the Consumer Federation of America (CFA), expressed strong opposition to the SEC’s proposed amendments aimed at expanding exemptions from securities registration requirements. Roper argued that these changes would significantly broaden […]

Letter to the SEC: Standard of Conduct for Investment Advisers and Broker-Dealers

Download Public Comment   Summary In her August 16, 2021, letter to the Securities and Exchange Commission (SEC), Barbara Roper, representing the Consumer Federation of America (CFA), responds to the SEC’s request for information on the effectiveness of Regulation Best Interest (Reg BI) and Form CRS. She argues that Reg BI has failed to meaningfully […]

Can the Internet Transform Disclosures for the Better

Download Report   Executive Summary At a time when the transition to a primarily Internet-based system of disclosure is well underway in the securities industry, this report examines how the Internet can be used to improve the effectiveness of financial disclosure. Toward that end, the report identifies potential benefits and pitfalls of Internet disclosure; the […]