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August 8, 2016

SEC Chair Mary Jo White Should Immediately Terminate the Disclosure Effectiveness Initiative, Which Contrary to her Statements, has no Basis

Monday, August 8, 2016
Contact: Nick Jacobs, 202-618-6430 or

Washington, D.C. – Dennis Kelleher, President and CEO of Better Markets, sent the attached letter to Securities and Exchange Commission (SEC) Chair Mary Jo White today requesting that she promptly terminate the so-called Disclosure Effectiveness Initiative (and the related Regulation S-K Concept Release), which, contrary to the Chair’s statements and testimony, lacks a statutory or factual basis:

“Contrary to SEC Chair White’s statements and testimony before the Senate Banking Committee and elsewhere, the SEC’s Disclosure Effectiveness Initiative has no statutory or factual basis.  Indeed, it appears to be based on nothing more than a staff decision, which appears to have been heavily influenced by the industry’s powerful past representatives on key American Bar Association (ABA) committees, including the current Director of the Division of Corporate Finance.

“In addition to having no statutory basis, as detailed in a July 21, 2016 Better Markets’ comment letter, the initiative is also purportedly based on an asserted crisis of investor ‘disclosure overload,’ but that is a myth.  The SEC has not provided any evidence that investors are seeking relief from too much disclosure.  Thus, this massive, resource-intensive initiative has no basis and was undertaken without the proper Commission consideration.

“The SEC should promptly terminate the Disclosure Initiative, withdraw the Concept Release, make Congressionally mandated rulemakings a priority, and focus its limited resources on investors’ interests above all else.”


Better Markets is a non-profit, non-partisan, and independent organization founded in the wake of the 2008 financial crisis to promote the public interest in the financial markets, support the financial reform of Wall Street and make our financial system work for all Americans again. Better Markets works with allies – including many in finance – to promote pro-market, pro-business and pro-growth policies that help build a stronger, safer financial system that protects and promotes Americans’ jobs, savings, retirements and more. To learn more, visit

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