Occupy the SEC works to ensure that financial regulators act in the public interest, not for Wall Street and its lobbyists. We are a group of concerned citizens, activists, and financial professionals with decades of collective experience working at many of the largest financial firms in the industry. If you live in NYC and would like to join us, or would like to help remotely, feel free to contact us.

New: OSEC Produces House Rankings

Recent Actions

Comment Letter to Securities and Exchange Commission Regarding Liquid Alternative Mutual Funds

November 25, 2014We submitted a letter to the Securities and Exchange Commission (“SEC”), recommending that the agency promulgate tough new regulations covering so-called “liquid alternative” mutual funds. In our letter, we warn the SEC about the outsized risks that these alternative funds present to investors and the economy. “Liquid alts” are a variety of mutual funds that promise high yields to investors, based on the utilization of risky investment strategies typically favored by the likes of hedge funds. These alternative funds have grown in popularity and growth estimates anticipate assets in liquid alternatives to amount to $2 trillion by 2020. The letter and the accompanying press release can be found below:

Comment Letter to U.S. Supreme Court in Omnicare v. Laborers

September 5, 2014We submitted an amicus brief in Omnicare, Inc. v. Laborers District Council Construction Industry Pension Fund, a case that is currently pending before the U.S. Supreme Court. The case centers on a key provision of the Securities Act of 1933 , Section 11, which creates an express right of action against issuers and their agents for material misrepresentations contained in the offering materials of registered securities. Section 11 is an important tool that aggrieved investors can use to seek remedy for misleading statements made by issuers and their agents. For example, Section 11 has been extensively used to combat the sort of shoddy-mortgage backed securities that led to the last recession. The brief and the accompanying press release can be found below:

Comment Letter to Commodity Futures Trading Commission Regarding Position Limit Regulations

August 7, 2014We submitted a comment letter to the Commodity Futures Trading Commission (“CFTC”) regarding that agency’s notice of re-proposed rulemaking regarding position limits on certain commodities contracts and derivatives. Unfortunately, the proposed position limits regime is rife with numerous exemptions, such as broadly permissive provisions for hedging. The CFTC’s proposed rules also fail to adequately regulate commodities speculation in non-spot months. In its comment letter, OSEC has recommended that the Commission promulgate simple and effective per se regulations that are both transparent and useful in regulating market conduct. The letter and the accompanying press release can be found below:

Comment Letter to Securities and Exchange Commission Regarding Clearing Agency Regulations

June 10, 2014We submitted a comment letter to the SEC regarding its request for comments on the its proposed clearing agency rules. As numerous commentators have asserted, swaps and other exotic OTC derivatives contributed to the recent financial crisis. The Dodd Frank Act has sought to shed light on these opaque markets, by requiring derivatives to be cleared through registered agencies. In some ways the risk associated with derivatives has not gone away - it has simply shifted to clearing agencies. Thus, it is vital that the Commission not only promulgate strong regulations covering such agencies, but also enforce such regulations in a vigorous manner. The letter and the accompanying press release can be found below:

Comment Letter to Federal Reserve Regarding Commodities Regulations for Banks

March 29, 2014We submitted a comment letter to the Federal Reserve regarding its request for comments on the current state of commodities regulation vis-a-vis banks and Systemtically Important Financial Institutions ("SIFIs"). As noted in our letter, banks must divest from commodities activities because the current status quo features a plethora of risks including:
  • system-wide proliferation of discrete environmental risks
  • market domination and antitrust risks
  • systemic magnification of commercial tail risks
The letter and the accompanying press release can be found below:

Comment Letter to FDIC Regarding the Resolutions of Too Big to Fail Institutions Under Title II of Dodd Frank

March 18, 2014We submitted a comment letter to the FDIC regarding its proposed rule implementing Title II of the Dodd Frank Act, which covers the orderly resolution of Systemtically Important Financial Institutions ("SIFIs") without putting any burden on taxpayers. OSEC has recommended that the FDIC impose stringent conditions on troubled SIFIs under resolution.

Comment Letter to Financial Regulators Regarding the Treatment of TruPS CDOs in the Volcker Rule

February 12, 2014We submitted a comment letter to the financial regulators regarding their recent concessions made to the industry on how to treat TruPS CDOs in the Final Volcker Rule

Letters to Congress Regarding the "Fairness for Community Job Creators Act"

January 21, 2014We submitted letters to both the House and Senate regarding companion bills that would carve out an exemption in the Volcker Rule for TruPS CDOs.