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 the use of private offering exemptions, undermining investor protection and the integrity of public markets.She criticized the SEC for proceeding without comprehensive analysis of the potential impacts on investors and market health, suggesting that the proposal was ideologically driven rather than based on solid economic evidence.
Roper highlighted concerns that the proposal would erode the distinctions between public and private markets, making it easier for companies to raise unlimited capital privately without adequate regulatory oversight or accountability.This shift, she warned, could lead to a decline in public market vitality, reducing transparency and protections for investors.She urged the SEC to halt the proposed amendments until a thorough analysis could be conducted to assess their effects on investor protection and the overall health of capital markets.
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 the use of private offering exemptions, undermining investor protection and the integrity of public markets. She criticized the SEC for proceeding without comprehensive analysis of the potential impacts on investors and market health, suggesting that the proposal was ideologically driven rather than based on solid economic evidence.
Roper highlighted concerns that the proposal would erode the distinctions between public and private markets, making it easier for companies to raise unlimited capital privately without adequate regulatory oversight or accountability. This shift, she warned, could lead to a decline in public market vitality, reducing transparency and protections for investors. She urged the SEC to halt the proposed amendments until a thorough analysis could be conducted to assess their effects on investor protection and the overall health of capital markets.
Read more…
Author
Barbara Roper
Senior Fellow
Latest Work
January 1, 2019
Journal Article
Touching, Tapping, and Talking: The Formation of Contracts in Cyberspace
November 24, 2025
Op-Ed
Stablecoin Risks Loom
August 9, 2021
Journal Article
A Rose Is A Rose: Electronic Commerce Spawns Word Confusion
January 1, 2023
Journal Article
The Impact of Value‑Based Payment Models for Networks of Care and Transmural Care
Related
DOL Alternative Investments Proposal Threatens Americans’ Retirement Security
Letter To DOL: Alternative Investments Proposal Threatens Americans’ Retirement Security
Letter to the SEC: Mutual Fund Disclosure Modernization
Letter to the SEC: Standard of Conduct for Investment Advisers and Broker-Dealers