Advocacy News and Action Items


NIRI Joins Society for Corporate Governance and NYSE on 13F Modernization Rulemaking Proposal

In April 2024, NIRI, the Society and the NYSE submitted a joint proposed SEC rulemaking to modernize Section 13(f) disclosure rules that would, among other things, reduce the quarterly disclosure period from 45 calendar days to five business days. NIRI requests that public companies join in supporting this proposal, and has made available a downloadable support letter template that can be tailored for each company. Please be sure to submit comment letters via email to “” and that File No. 4-825 is noted in the subject line.

NIRI Joins Business Coalition Comment Letter Regarding PCAOB Audit Expansion Proposal

In August 2023, NIRI joined a coalition of business trade and professional societies in submitting a joint comment letter to the PCAOB regarding its proposal to dramatically expand the scope, time and expense of audits, costs that will ultimately be borne by public companies.

NIRI Submits Statement to House Financial Services Committee on Financial Regulatory Reform Issues  

NIRI submitted a statement on the record regarding several of the proposals considered at the House Committee on Financial Services hearing on July 12, 2023. These issues include support for NIRI's recommendation to establish an SEC Public Company Advisory Committee, and proxy advisory firm oversight reform, among others.

SEC Releases Climate Risk Disclosure Rule Proposal

In March 2022, U.S. Securities and Exchange Commission released a proposed rule to mandate certain climate-related disclosures by public companies. As drafted, the SEC’s proposal would require all public companies to:

  • disclose information about their internal processes to identify, assess, manage and oversee climaterelated risks
  • disclose how any identified climate-related risks have had, or are likely to have, a material impact on their businesses and consolidated financial statements over various periods of time
  • disclose how any identified climate-related risks have affected, or are likely to affect, each company’s strategy, business model, and outlook
  • disclose information about any transition plans, scenario analyses, or carbon price metrics that a company may have adopted to address climate-related issues
  • disclose the impact of any climate-related events (i.e., severe weather events and other natural conditions) within its financial statements.

NIRI held a Town Hall meeting to review this rule proposal and to gather feedback. To further help inform its comment letter to the SEC, NIRI encouraged members to submit their thoughts, questions and concerns regarding this rule proposal to NIRI.

NIRI Expresses Support for 13F Reform Legislation

On May 5, 2021, NIRI submitted a letter in support of the “Capital Markets Engagement and Transparency Act of 2021,” which would modernize the Section 13(f) ownership disclosure rules. This draft bill was among the bills slated for consideration during the House Financial Services Committee's May 6 hearing on market volatility and short selling. 

The bill would: (1) shorten the Form 13F filing deadline from 45 days to five business days; (2) improve the timeliness of 13F disclosures by requiring monthly disclosure instead of quarterly reporting; (3) require that 13F filers disclose their short positions; (4) require the disclosure of derivative positions that are substantially equivalent economically to direct ownership of a 13F security; and (5) direct the SEC to complete a study of its current standards for granting confidential treatment requests to investment managers who wish to delay specific 13F disclosures.

NIRI encourages companies and NIRI chapters to contact House lawmakers to voice their support for these much needed reforms. For more information, please contact Niels Holch, NIRI's Vice President for Public Policy and Advocacy


NIRI Submits Letter in Response to SEC's Call for Input on Climate Risk Disclosure

NIRI has submitted a comment letter to the SEC in response to the Commission's March 15, 2021 request for investors, companies, and other market participants to share their views on climate change disclosure and reporting frameworks. NIRI encourages companies to also share their views with the SEC. 

"Since 2010, investor demand for, and company disclosure of information about, climate change risks, impacts, and opportunities has grown dramatically," Acting SEC Chair Allison Herren Lee said in a statement. "Consequently, questions arise about whether climate change disclosures adequately inform investors about known material risks, uncertainties, impacts, and opportunities, and whether greater consistency could be achieved."

The agency's request for public input includes 15 separate groups of questions related to dislcosure. Here are three of the question groups that the SEC has included:

  • What are the advantages and disadvantages of permitting investors, registrants, and other industry participants to develop disclosure standards mutually agreed by them? Should those standards satisfy minimum disclosure requirements established by the Commission? How should such a system work? What minimum disclosure requirements should the Commission establish if it were to allow industry-led disclosure standards? What level of granularity should be used to define industries (e.g., two-digit SIC, four-digit SIC, etc.)?
  • What are the advantages and disadvantages of establishing different climate change reporting standards for different industries, such as the financial sector, oil and gas, transportation, etc.? How should any such industry-focused standards be developed and implemented?
  • What are the advantages and disadvantages of rules that incorporate or draw on existing frameworks, such as, for example, those developed by the Task Force on Climate-Related Financial Disclosures (TCFD), the Sustainability Accounting Standards Board (SASB), and the Climate Disclosure Standards Board (CDSB)? Are there any specific frameworks that the Commission should consider? If so, which frameworks and why? 
NIRI members and chapters are also encouraged to submit their thoughts directly to the SEC. NIRI has provided a draft comment letter template to be used as a starting point, available for download here

NIRI Joins Trade Group Letter in Support of Equality Act  

On Feb. 24, 2021, NIRI joined a business trade association letter organized by the National Association of Manufacturers in support of the Equality Act (H.R. 5). The legislation would amend several provisions of the Civil Rights Act of 1964 to provide affirmative, statutory non-discrimination protections for LGBTQ Americans both in the workplace and in the community.  While this bill was approved by the U.S. House of Representatives on a 224-to-206 vote, this legislation faces an uphill fight in the Senate, where 60 votes would be needed to overcome a filibuster by opponents.  

Issuer Coalition Urges House to Improve Ownership Transparency 

In advance of the U.S. House Financial Services Committee's February 2021 hearing on GameStop and short selling, the Shareholder Communications Coalition, which includes NIRI, submitted a statement calling for short position transparency and modernization of the 13D and 13F disclosure rules.  

On March 31, Americans for Financial Reform, a coalition of labor pension funds and other investor advocates, wrote a letter to the SEC that urged the agency to modernize the 13F rules by expanding disclosure to include short sales, short option positions, and derivatives. The group also asked the SEC to increase its regulatory scrutiny of "family offices," citing the collapse of Archegos Capital and the efforts of several prominent hedge fund managers to evade oversight by converting to family office structures.