In a comment letter to the Securities and Exchange Commission (SEC), the ASA expressed concerns regarding the Division of Enforcement’s Mutual Fund Share Class Selection Disclosure Initiative and subsequent regulation by enforcement. To read the full letter, click here.
The ASA asked the Commission to adopt its suggested language and solutions to eliminate investor confusion and preserve both service models (i.e. advisory and brokerage).
The American Securities Association (ASA) supports House passage of the “JOBS Act and Investor Confidence Act of 2018” (JOBS Act 3.0). The ASA’s support is derived from the diversity of our membership, the different business models of our membership, and the deep experience our members have in helping small businesses access the U.S. capital markets.
S. 1117 addresses an issue of government regulation picking winners and losers. Because of this, municipalities are being forced to seek higher cost borrowing options, reduce their short-term capital consumption, and terminate infrastructure projects that benefit their communities. By forcing municipal investors out of prime and tax-exempt funds and into government funds, the SEC’s floating NAV rule has increased costs on taxpayers and businesses without any material benefit, other than creating artificial demand for U.S. government deficit spending. ASA… read more →
The American Securities Association (ASA) welcomes the opportunity to comment on the Securities Exchange Commission’s (SEC or Commission) proposed Transaction Fee Pilot for NMS Securities (Pilot). The ASA’s comments set forth in this letter are derived from the diversity of our membership, the different business models of our membership, and the vast experience our members have transacting in the U.S. equity markets.
The Corporate Governance Coalition for Investor Value (the “Coalition”) was formed to provide a forum to advocate for strong corporate governance policies and federal securities laws that promote long-term value creation for investors. The Coalition strongly supports H.R. 4015, the Corporate Governance Reform and Transparency Act, which would provide for effective oversight of proxy advisory firms. 180627_Coalition_HR4015_Crapo_Brown
The EDA was proud to be a part of such an important policy goal: making it easier for small companies to go public and stay public. This is not only good for small businesses, but it is also necessary for our economy to continue to grow and create jobs.
For Immediate Release May 22, 2018 The Equity Dealers of America Applauds Launch of New Retail Investor Education Campaign Earlier this morning the Equity Dealers of America and other leading national member associations launched a first of-its-kind education and advocacy campaign, aimed at prioritizing the interests of retail investors. Titled the Main Street Investors Coalition, the new initiative is intended to address an investment system which has become increasingly politicized in recent years and which systematically disadvantages every-day investors.… read more →
EDA and a group of diverse industry organizations came together to offer policymakers and regulators important recommendations to strengthen U.S. public capital markets by making it easier for more companies to go public and stay public. The report focuses on the following: Enhancements to the JOBS Act; Recommendations to Encourage More Research of Emerging Growth Companies and Other Small Public Companies; Improvements to Certain Corporate Governance, Disclosure, and Other Regulatory Requirements; Recommendations Related to Financial Reporting; and Equity Market Structure.… read more →
The EDA filed a brief at the Supreme Court in the Lucia v. SEC case, which will be heard in early April. The EDA believes important Constitutional issues exist in this case with respect to Due Process and Separation of Powers. We asked the Supreme Court to reverse the judgment of the United States Court of Appeals for the District of Columbia Circuit on these issues in an effort to preserve the basic constitutional protections provided by the founders of… read more →
In the wealth management business there are two models: one in which the financial advisors (FAs) are independent contractors and are eligible for the pass-through tax treatment and the other model in which the FAs are employees (Employee FAs) and not eligible for the pass-through tax treatment. We believe that adopting language in the tax code that chooses one business model over another was an unintended consequence of the tax reform effort, and that it can be corrected. EDA Letter to… read more →
EDA submitted a letter asking the SEC to create a uniform best interest standard for broker-dealers and investment advisors using the DOL Impartial Conduct Standards as its baseline. Letter to SEC on Best Interest Standard 2017
Reforming the capital markets has become a priority for investors, issuers, public equity firms, and regulators in the wake of the dramatic decline in the number of public companies in the U.S. The EDA had the chance to discuss how to achieve this objective with NASDAQ. https://listingcenter.nasdaq.com/clearinghouse.aspx#qna
EDA strongly supports efforts to improve the capital formation process, the secondary trading, and the research environment for small businesses. Increased access to capital will lead to job creation. Small Business Access to Capital Submission to Treasury
The EDA is a member of the Corporate Governance Coalition for Investor Value, which sent a letter today to the SEC asking it to increasing its shareholder proposal re-submission thresholds. The coalition believes that “[r]ule14a-8 increasingly has been used by a minority of activist shareholders to promote agendas that are uncorrelated to enhancing long-term value for shareholders” who waste company resources by submitting “the same proposals year after year”. CGCIV Final Resubmission Thresholds letter (002)
The EDA sent a letter to FINRA recommending that it not move forward with its Proposal to provide a safe harbor for desk commentary. The EDA believes that the Proposal is not workable, it lacks an adequate cost-benefit analysis, it misconstrues how the sales and trading business of its membership works in practice, and it puts examiners in the unenviable position of evaluating desk commentary under the subjective “I know it, when I see it” standard. The Proposal imposes the… read more →
The Equity Dealers of America submitted a comment letter to the SEC urging the agency to decline to approve a rule proposal from Bats Exchange that would further complicate the equity market structure and add little to no value to market participants. EDA Letter to SEC on Bats Proposal SR-BatsBZX-2017-34
EDA, along with several other trades, expresses its concerns with Nevada law SB 383, which removes the exemption for broker-dealers from the definition of financial planner. Final Joint Letter to Foley_June 23 2017 (002)
The Equity Dealers of America (EDA) appreciates the opportunity to comment on the Financial Industry Regulatory Authority’s (FINRA) notice regarding potential enhancements to certain engagement programs (Engagement Notice). Read the Full Letter