Letter from Fund Democracy, Consumer Federation of America, AARP, Public Citizen’s Congress Watch, Americans for Financial Reform, to Office of Management and Budget responding to Congressional letter on Department of Labor rulemaking (Oct. 18, 2013)

Letter from Fund Democracy, et al., to SEC Chair Mary Jo White on request for information regarding fiduciary rulemaking (June 4, 2013)

Letter From Fund Democracy and Consumer Federation of America on proposed amendments to Rule 506 (May 15, 2013)

Letter From Fund Democracy, et al., on proposed amendments to Rule 506 (Apr. 29, 2013)

Letter from Fund Democracy to SEC on proposed amendments to Rule 506 (Oct. 2, 2012)

Letter from Fund Democracy (co-signed by AARP, CFA, AFR, AFL-CIO, AFSCME, U.S. PIRG, and Public Citizen) to SEC on amendments to Rule 506 and SEC intent to adopt rule without notice and comment (Aug. 16, 2012)

Letter from Fund Democracy, Consumer Federation of America, Consumer Action, AFL-CIO and Americans for Financial Reform to SEC on requirement for reasonable accredited investor verification steps pursuant to amendments to Rule 506 (May 24, 2012)

Letter from Fund Democracy and the Consumer Federation of America commenting on SEC 12b-1 fee proposal (Nov. 5, 2010)

Letter from Fund Democracy and the Consumer Federation of America commenting on SEC proposal regarding pay-to-play practices (Oct. 6, 2009) 

Letter from Fund Democracy and the Consumer Federation of America commenting on SEC money market fund proposal (Sep. 8, 2009)

Letter from Fund Democracy and the Consumer Federation of America to SEC and Department of Labor commenting on regulation of target date funds (June 18, 2009)

Letter from Fund Democracy to Fed Chairman Bernanke regarding money market funds and systemic risk (Apr. 3, 2009)

Letter from Fund Democracy to Treasury Secretary Geithner regarding money market funds and systemic risk (Apr. 2, 2009)

Letter from Fund Democracy and Consumer Federation of America to Chairman Kohl and Ranking Member Martinez, Senate Special Committee on Aging, regarding target date funds (Apr. 2, 2009)

Letter from Fund Democracy to Chairman Andrews and Ranking Member Kline, House HELP Subcommittee, regarding equal access proposal for independent and conflicted advisers to 401k beneficiaries (Mar. 26, 2009) (letter was follow-up to HELP testimony)

Testimony on the importance of independent investment advisory services provided to defined contribution plan participants before the Subcommittee on Health, Employment, Labor, and Pensions, Committee on Labor and Education, U.S. House of Representatives (Mar. 24, 2009)

Letter from Fund Democracy, Consumer Federation of America, Consumer Action, National Association of Personal Financial Advisors, Pension Rights Center, AFL‐CIO, and National Retiree Legislative Network to Chairman Andrews and Ranking Member Kline, House HELP Subcommittee, regarding importance of independent investment advisory services provided to defined contribution plan participants (Mar. 24, 2009)

Hecker v. Deere & Co., Petition for Panel Rehearing or Rehearing en banc by amici curiaeAARP, Senior Citizens Law Center, Pension Rights Center, Fund Democracy and Consumer Federation of America (Mar. 16, 2009) (see also law professors’ petition)

Testimony on enhancing investor protection and the regulation of the securities markets before the Senate Committee on Banking, Housing and Urban Affairs (Mar. 10, 2009) (not limited to MMFs; includes general investor protection issues)

Letter from Fund Democracy and Consumer Federation of America to Employee Benefits Security Administration, Department of Labor, commenting on proposal regarding the providing of conflicted advice to 401k beneficiaries (Oct. 6, 2008)

Letter from Fund Democracy, Consumer Federation of America, Consumer Action, National Association of Personal Financial Advisors, and Financial Planning Association requesting that SEC act promptly on January 2008 petition to require nonpublic electronic filing of portfolio information by money market funds (Sep. 22, 2008) (January 2008 petition)

Letter from Fund Democracy and Consumer Federation of America to Chairman Kennedy and Ranking Member Enzi, Senate Health, Education, Labor, Pensions Committee, regarding regulation of disclosure of fee information to 401k beneficiaries (Sep. 22, 2008) (related EBSA comment letter; related Senate Special Committee on Aging testimony)

Letter from Fund Democracy and Consumer Federation of America to Securities and Exchange Commission in support of proposal regulate equity-indexed annuities as securities under the federal securities laws (Sep. 10, 2008)

Letter from Fund Democracy, Consumer Federation of America to Employee Benefits Security Administration, Department of Labor, commenting on proposed regulation of disclosure of fee information to 401k beneficiaries (Sep. 8, 2008) (related Senate Special Committee on Aging testimony)

Letter from Fund Democracy and Consumer Federation of America commenting on SEC proposal to weaken investor protections by eliminating NRSRO rating requirement from money market fund rule (Sep. 5, 2008)

Fund Democracy, Consumer Federation of America, Consumer Action and NASAA ask SEC for interpretive position that Sarbanes-Oxley whistleblower provision generally applies to fund manager employees (Mar. 28, 2008) (letter)

Fund Democracy, the Consumer Federation of America, and Consumer Action comment on SEC proposal to permit mutual funds to use a summary prospectus to satisfy prospectus delivery requirement (Feb. 28, 2008)(letter) & (Apr. 17, 2008) (follow-up letter)

Fund Democracy, the Consumer Federation of America, Consumer Action, AFL-CIO, Financial Planning Association, and National Association of Personal Financial Advisors petition SEC to require money market funds to file portfolios electronically with SEC (Jan. 16, 2008) (letter)

Fund Democracy comment letter on SEC proposal to require electonic filing of exemptive applications under the Investment Company Act (Dec. 14, 2007) (letter)

Study by Mercer Bullard, Geoff Friesen and Travis Sapp shows larger performance gaps for shareholders who buy funds through conventional distribution arrangements (Dec. 6, 2007) (studyBullard statement)

Fund Democracy and Consumer Federation of America letter commenting on SEC’s proposed exemption from principal trading restrictions (Nov. 30, 2007) (letter)

Fund Democracy and Consumer Federation of America letter to SEC regarding reproposal of rule relating to broker exclusion from definition of investment adviser (Nov. 2, 2007) (letter)

Fund Democracy testimony before the Senate Special Committee on Aging on 401(k) fee disclosure (Oct. 24, 2007) (Testimony Statement Chart)

Fund Democracy and Consumer Federation of America letter to DoL’s Employee Benefits Security Administration regarding fee disclosure for individual accounts (e.g., 401(k) plans) (July 24, 2007) (letter)

Fund Democracy testimony before Subcommitte on Domestic Policy, House Committee on Oversight and Government Reform regarding investment company status and regulation of hedge fund managers (July 11, 2007) (testimony)

Fund Democracy releases preliminary memorandum on the status of Blackstone as an investment company (June 20, 2007) (letter)

Fund Democracy and Consumer Federation of America write to OMB in support of DOL proposal to exclude capital preservation vehicles as qualified default investments (June 18, 2007) (letter)

Regulator, consumer and adviser groups ask SEC to clarify brokers’ legal duties in wake of court decision vacating the broker-dealer exemption (Apr. 24, 2007) (letter)

Fund Democracy and Consumer Federation of America comment on SEC studies relating to fund governance proposals (Mar. 2, 2007) (letter SEC Economic Study: Power Study SEC Economic Study: Literature Review)

Documents/links relating to Zero Alpha Group/Fund Democracy study finding that investors who buy funds through brokers pay a broker penalty in the form of being placed in funds with higher operating expenses (Nov. 30, 2006)(study Bullard press conference statement news release)

Letter from Fund Democracy and the Consumer Federation noting that BISYS enforcement action further demonstrates need for the independent fund chairman rule (Oct. 18, 2006) (letterenforcement action)

Letter from Fund Democracy and the Consumer Federation of America commenting on SEC proposal to require that mutual fund boards be 75% independent and have an independent chairman (Aug. 21, 2006) (letter)

Letter from Fund Democracy and the Consumer Federation of America commenting on SEC draft request for proposals to conduct study of brokerage and investment adviser industries (July 19, 2006) (letter SEC Request)

Supplemental letter to court from Fund Democracy and the Consumer Federation of America in connection with FPA challenge to SEC rule exempting brokers from regulation under the Advisers Act (June 28, 2006) (letter)

Letter from Fund Democracy and the Consumer Federation of America commenting on the SEC Chairman’s XBRL initiative (June 2, 2006) (letter SEC Chairman speech re XBRL initiative)

Letter from Fund Democracy, Consumer Federation of America, Consumer Action, AARP and Consumers Union to SEC Chairman Cox urging a prompt request for comments on the costs of compliance with the independent chairman/75% independent board rule (Apr. 18, 2006) (letter)

Amicus brief filed by Fund Democracy and Consumer Federation of America in opposition to SEC rule exempting brokers from regulation under the Advisers Act (Apr. 10, 2006) (brief)

Letter from from Fund Democracy and Consumer Federation of America to SEC Chairman Cox regarding staff interpretation of broker exemption dated Dec. 16, 2005 (Feb. 15, 2006) (letter SEC staff interpretation)

Comment letter from Fund Democracy and Consumer Federation of America regarding SEC interpretive release on soft dollar safe harbor (Nov. 23, 2005) (comment letter SEC interpretation)

Amicus brief filed by Fund Democracy and Consumer Federation of America urging dismissal of Chamber of Commerce challenge to fund governance rules (Oct. 28, 2005) (amicus briefpress release: related third party documents: SEC briefChamber of Commerce briefCourt of Appeals decision)

Letter from Consumer Federation of America and Fund Democracy to Chairman Cox regarding broker exemption (Sep. 30, 2005) (letter)

Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union asking SEC to reject SIA’s and ACLI’s requests to extend compliance date for broker exemption (Aug. 11, 2005) (letter & SEC decision)

Letter and press release from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union in support of Senator Akaka’s Mutual Fund Transparency Act of 2005 (May 16, 2005) (letter — press release)

Comment Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union responding to SEC request for comment on mutual fund point-of-sale document proposal (April 5, 2005) (letter — original comment letter — SEC request for further comment —original SEC proposal)

Fund Democracy and Consumer Federation of America response to letter from Chairmen Oxley and Baker to SEC regarding proposal to exempt certain fee-based brokers from adviser regulation (April 4, 2005) (letter — Oxley-Baker letter)

Comment Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union on SEC proposal to exempt certain fee-based brokers from adviser regulation (Feb. 7, 2005) (letter — related letter on legislative history of the broker exclusion)

Press Release from Fund Democracy, AARP, Consumer Federation of America, Consumer Action and Consumers Union on testing of mutual fund disclosure on point-of-sale document (Dec. 14, 2004) (press release)

Letter from Fund Democracy, AARP, Consumer Federation of America, Consumer Action and Consumers Union on testing of mutual fund disclosure on point-of-sale document (Dec. 6, 2004) (letter)

Statement by Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union regarding lawsuit filed by the Financial Planning Association challenging the SEC’s proposed rule expanding the broker exclusion from the Investment Advisers Act (July 20, 2004) (statement)

Comment letter from Fund Democracy and Consumer Federation of America on SEC proposal to require most mutual funds to impose a 2% redemption fee on shares sold within 5 days of purchase (May 11, 2004) (letter)

Comment Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union on SEC proposal regarding mutual funds’ use of brokerage commissions to finance distribution (May 10, 2004)(letter — proposing release)

Comment Letter by Fund Democracy and Consumer Federation of America on SEC proposal regarding disclosure of the basis of mutual fund boards’ approval of the advisory contract (Apr. 26, 2004) (letter — proposing release — adopting release)

Comment Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union on SEC proposal regarding fee disclosure in mutual fund point-of-sale and confirmation documents (Apr. 21, 2004)(letter proposing release)

Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union to SEC Chairman Donaldson regarding his testimony before the Senate Banking Committee on 4/8/2004 (Apr. 14, 2004) (letter)

Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union to Senate Banking Committee regarding testimony of SEC Chairman Donaldson dated 4/8/2004 (Apr. 13, 2004) (letter)

Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union to Senate Banking Committee regarding need for legislation (Apr. 7, 2004) (letter)

Comment Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union on SEC request for comments on measures to improve disclosure of mutual fund portfolio transaction costs (Mar. 16, 2004) (letter)

Comment letter from Fund Democracy, Consumer Federation of America, Consumer Action, Consumers Union and Public Citizen on SEC proposal regarding investment company governance (Mar. 10, 2004) (letter proposing release adopting release)

Letter to the Wall Street Journal from Fund Democracy and Consumer Federation of America responding to editorial by Fidelity Chairman Edward C. Johnson regarding SEC proposal to require an independent fund chairman (Feb. 18, 2004) (letter)

Comment Letter from Fund Democracy and Consumer Federation of America on SEC proposal regarding improving disclosure of mutual fund commission breakpoints (Feb. 12, 2004)(letterproposing release adopting release)

Comment Letter from Fund Democracy and Consumer Federation of America on SEC proposal to require receipt of fund orders no later than the time the fund is priced (usually 4:00 pm est) (Feb. 6, 2004) (letter proposing release)

Letter from Fund Democracy, Consumer Federation of America, Consumer Action, Consumers Union and U.S. Public Interest Research Group to Senator Peter Fitzgerald in support of the Mutual Fund Reform Act (Feb. 5, 2004) (letter)

Statement by Fund Democracy on Zero Alpha Group study on hidden fund portfolio transaction costs (Jan. 23, 2004) (statement)

Press release from Fund Democracy, Consumer Federation of America, Consumer Action, Consumers Union and U.S. Public Interest Research Group regarding mutual fund reform issues, including SEC proposal to permit advisers to serve as subadvisers to mutual funds without shareholder approval (Jan. 12, 2004) (press release)

Comment Letter from Fund Democracy and Consumer Federation of America on SEC proposal regarding advisers acting as subadvisers to mutual funds without shareholder approval (Jan. 8, 2004) (letter)

Press release from Fund Democracy, Consumer Federation of America, Consumer Action, Consumers Union and U.S. Public Interest Research Group in connection with release of Blueprint for Mutual Fund Reform (Nov. 25, 2003) (press release)

Blueprint for Mutual Fund Reform (Nov. 25, 2003) (press release blueprint)

Press release from Fund Democracy and Consumer Federation of America regarding overpriced money market funds and index funds (July 23, 2003) (press release)

Letter from Fund Democracy in support of amendment to H.R. 2420, The Mutual Funds Integrity and Fee Transparency Act of 2003, that would prohibit certain misleading fund names (July 22, 2003) (letter)

Letter from Fund Democracy, Consumer Federation of America, Consumer Action and Consumers Union in support of H.R. 2420,The Mutual Funds Integrity and Fee Transparency Act of 2003 (July 9, 2003)(letter)

Letter from Fund Democracy to House Subcommittee on Capital Markets following up on testimony dated 6/18/03 (July 9, 2003) (letter)

Letter from Fund Democracy, Consumer Federation of America, Investment Counsel Association of America, Financial Planning Association, certified Financial Planner Board of Standards, Inc., and the National Association of Personal Financial Advisors to SEC Chairman Donaldson regarding SEC proposal to expand the exemption for brokers who provide investment advice from regulation as investment advisers (May 6, 2003) (letter proposing release)

Press Release issued by Fund Democracy, Consumer Federation of America, Investment Counsel Association of America, Financial Planning Association, certified Financial Planner Board of Standards, Inc., and the National Association of Personal Financial Advisors regarding letter to SEC Chairman Donaldson regarding SEC proposal to expand the exemption for brokers who provide investment advice from regulation as investment advisers (May 6, 2003) (press release)

Letter from Fund Democracy, Consumer Federation of America, Financial Planning Association, Consumers Union, Consumer Action, U.S. Public Interest Research Group, Citizens Funds, Social Investment Forum, Domini Funds, National Association of Personal Financial Advisers, AARP, CalPERS, AFL-CIO, The Catholic Funds, CorpGov.net, and Robert Monks to Office of Management and Budget in support of SEC rule requiring mutual funds to disclose how they vote proxies relating to their portfolio securities (Mar. 6, 2003) (letter)

Comment Letter from Fund Democracy and Consumer Federation of America on SEC proposal regarding mutual fund portfolio and fee disclosure (Feb. 14, 2003) (letter)

Statement of Mercer Bullard, Founder and President, Fund Democracy, at Pax World News Conference (Jan. 23, 2003) (statement)

Comment letter from Fund Democracy regarding SEC proposal to require mutual funds to disclose their proxy-voting policies and records (Dec. 8, 2002) (second letter proposing release adopting release)

Comment letter from Fund Democracy regarding SEC proposal to require mutual funds to disclose their proxy-voting policies and records (Oct. 21, 2002) (first letter proposing release adopting release)

Statement of Mercer Bullard, Founder and President, Fund Democracy, at Pax World News Conference (Oct. 22, 2002) (statement)

Memorandum by Fund Democracy in support of rulemaking petition regarding more frequent portfolio disclosure, misleading fund names, and electonically accessible filing of information (June 28, 2000) (memorandum)

Rulemaking petition by Fund Democracy regarding more frequent portfolio disclosure, misleading fund names, and electonically accessible filing of information (June 28, 2000) (petition proposing release adopting release)

Testimony before the Committee on Economic Matters, Maryland House of Delegates regarding Senate Bill 264, which provides effective immunity for independent fund directors (Mar. 28, 2001) (testimony)

Letter to SEC regarding applicant’s response to Fund Democracy’s request for hearing on exemptive application filed by Hillview Investment Trust for an exemption from section 15(a) of the Investment Company Act (Mar. 12, 2001) (letter)

Request for a hearing by Fund Democracy on on exemptive application filed by Hillview Investment Trust for an exemption from section 15(a) of the Investment Company Act

Request for a hearing by Fund Democracy on on exemptive application filed by Barclays to permit it to offer certain exchange traded funds (May 4, 2000) (hearing request)

Memorandum in support of request for hearing by Fund Democracy on application to permit adviser to serve as subadviser to mutual fund without shareholder approval (Mar. 5, 2001) (memorandum)

Request for Hearing by Fund Democracy on application to permit adviser to serve as subadviser to mutual fund without shareholder approval (Mar. 5, 2001) (hearing request)

Letter to Charles Jaffe, Boston Globe (Dec. 28, 2000) (letter)

Letter to Mutual Funds Magazine (Dec. 22, 2000) (letter)

Activists, Advisors Press for Better Mutual Funds Disclosure, NAPFA Advisor (Dec. 2000) (articleabstract)

Memorandum in support of petition for rulemaking to require mutual funds to: (1) use names suggesting that they invest in a particular type of security only if 85% of their assets are invested in that type of security; (2) publicly report their portfolio holdings on a monthly basis within 60 days after the end of each month, with exceptions granted by the Commission on a case-by-case basis, and (3) post portfolio holdings on the Internet in a format that is easy to download and analyze, and provide paper copies of this information upon request (June 28, 2000)(memorandumsubsequent release prohibiting misleading fund names rulesubsequent release requiring more frequent portfolio disclosure)

Petition for rulemaking to require mutual funds to: (1) use names suggesting that they invest in a particular type of security only if 85% of their assets are invested in that type of security; (2) publicly report their portfolio holdings on a monthly basis within 60 days after the end of each month, with exceptions granted by the Commission on a case-by-case basis, and (3) post portfolio holdings on the Internet in a format that is easy to download and analyze, and provide paper copies of this information upon request (June 28, 2000) (petitionsubsequent release prohibiting misleading fund names rulesubsequent release requiring more frequent portfolio disclosure)

Letter from Fund Democracy withdrawing request for hearing on ETF exemptive application (May 11, 2000) (letter)

Letter supplementing Memorandum in Support of Hearing Request dated 5/4/00 regarding request for a hearing on ETF exemptive application (May 9, 2000) (letter)

Memorandum in support of request for a hearing on ETF exemptive application (May 4, 2000) (memorandum)

Request for a hearing on ETF exemptive application (May 4, 2000) (hearing request)