From Chair Clayton’s speech yesterday:
Since the April 2018 proposal, we have engaged with Main Street investors across the United States to discuss their experiences. SEC staff organized a series of seven roundtables around the country, providing Main Street investors an opportunity to speak directly with me, my fellow Commissioners and senior SEC staff—all in an effort to improve the proposed rules. It is clear, based on these discussions, that we have the right perspective, namely, that the core obligations of investment professionals—and mandatory plain language disclosures—should match reasonable investor expectations.
The efforts of the SEC staff to deliver for Main Street investors in this important area have been exemplary. In addition to the investor roundtables, we launched a new webpage where investors can view samples of the proposed disclosure form and submit feedback. The SEC’s Office of the Investor Advocate engaged the RAND Corporation to conduct investor testing of the proposed disclosure form and has made the report available for review and public comment. Our staff has been carefully reviewing all of this information, and the more than 6,000 comment letters, as they work diligently to develop final recommendations.
George Michael Gerstein advises financial institutions on the fiduciary and prohibited transaction provisions of ERISA. As co-chair of the fiduciary governance group, he assists clients with tracking, and understanding, the numerous fiduciary developments at the federal and state levels, including the rules and regulations of governmental plans. He also advises clients with respect to the fiduciary duty implications of ESG investing.