To improve markets and safeguard investors, we share our expertise and insights with policymakers worldwide.
Washington, D.C., and beyond
We engage with policymakers by regularly commenting on policy proposals, providing experts to testify before Congress and other panels, and working with lawmakers, regulators, and their staffs on issues important to investors and the financial markets.
We work with policymakers to strengthen the stability and efficiency of financial markets for the best interests of investors.
Mutual funds and ETFs continue to help investors reach their financial goals. We support policies that simplify and lower the cost of investing, promote transparency, and improve the investor experience.
We engage with policymakers on how to make it easier for individuals to save and invest to meet their needs for a secure retirement.
We support tax policies that promote long-term saving and investing, such as preserving tax incentives for employer-sponsored retirement plans.
Trading and markets
We work with policymakers to support transparent, efficient, and liquid markets to serve the interests of all investors.
Vanguard filed a comment letter in response to the Security and Exchange Commission’s December 2021 proposed rule on money market fund reform. In general, we support the SEC’s proposed rule, particularly its provisions to eliminate liquidity fees and redemption gates and to increase daily and weekly liquidity requirements. We believe these provisions are critical to improving the resilience of money market funds in periods of market stress.
Learn why we believe the DOL proposal will benefit plan participants and beneficiaries by giving fiduciaries greater certainty that their investment and proxy voting decisions may consider other factors that are material to the risk-return analysis, including factors related to environmental, social, or governance considerations.
Vanguard believes that diversity, equity, and inclusion are essential to our success in serving our 30 million clients. We support a recent House bill that would make meaningful investments in historically Black colleges and universities (HBCUs).
Vanguard urges the SEC to propose rules that will provide clear, concise, and meaningful climate-related disclosure that enables investors to make informed decisions based on consistent and comparable disclosures.
Vanguard supports bipartisan efforts in Congress to strengthen retirement security, including legislation introduced in the Senate that would expand automatic enrollment, raise the age for required minimum distributions to 75, and allow 403(b) plans to invest in collective investment trusts.
Vanguard recommends MMF reforms to the SEC, including a floating net asset value (NAV) for all prime MMFs, further consideration of stable NAV for tax-exempt MMFs with additional liquidity protections, and the elimination of fees and gates for all types of MMFs.
Learn why we support the Securing a Strong Retirement Act, a House bill that would allow for greater choice in investments, improve participant decision-making, increase the age for required minimum distributions, and simplify retirement plan administration.
Learn our views on the FTC’s proposal to modernize the federal premerger notification program, including our recommendations for making the FTC’s proposal less costly for investors. The premerger program provides the FTC and the Department of Justice with information about large mergers and acquisitions before they occur.
Vanguard weighs in on an FTC request for comment on whether the activities of mutual funds continue to meet the definition of “solely for the purpose of investment,” in light of investors’ increasing engagement on matters of corporate governance.
Vanguard supports the SEC’s proposal to modernize disclosure for open-end management investment companies by providing an engaging disclosure framework that gives investors timely access to key information. We also make several recommendations to further strengthen the proposal.
Vanguard urges the Department of Labor (DOL) to adopt a principles-based framework and ensure that securities voting practices for ERISA fiduciaries are implemented for the economic benefit of plan participants and beneficiaries.
Learn our views on a DOL proposal on selecting plan investments and why we believe that investors should have the choice to avoid investment risks, including those associated with environmental, social, and governance (ESG) considerations.
The Board of Trustees of the Vanguard Funds highlights four key areas of focus for clarifying how fund boards of directors and trustees can fulfill their statutory valuation responsibilities in light of market and other developments in the fund industry.
Vanguard saw opportunities to further strengthen customer protections in a proposal by the CFTC that would update the insolvency procedures for FCMs, while also distinguishing updated procedures for DCOs.
Vanguard supports a proposal by the CFTC regarding a real-time reporting framework for swaps and offers recommendations to strengthen the current SEF regulations in order to enhance transparency and price discovery within the swaps market.
Vanguard weighs in on whether the existing rule on fund names is effective in prohibiting funds from using names that are materially deceptive or misleading, and on whether the rule should apply to ESG-focused funds.
Vanguard supports IEX’s proposal to add a new order type, that would benefit investors by increasing liquidity among a more diverse group of market participants. We urge the SEC to approve the innovative proposal.
Learn why Vanguard believes the practice of “post-trade name give-up” for cleared swap transactions exposes the positions of market participants and why we think eliminating the practice would enhance liquidity.
Vanguard makes a recommendation in response to the SEC’s proposal to update the procedural requirements that a shareholder must satisfy to include a proposal in a company’s proxy statement under Rule 14a-8. Our recommendation is intended to further align Rule 14a-8 with shareholder value.
Vanguard filed a comment letter in response to the Securities and Exchange Commission’s (SEC) rule proposal, TheEnhancement and Standardization of Climate-Related Disclosures for Investors. Our letter generally supports the SEC’s proposal, which provides clear, consistent, and comparable foundational climate-related information, including uniform reporting of greenhouse gas (GHG) emissions generated directly by reporting companies (Scope 1) as well as those generated indirectly from purchased energy consumed by reporting companies (Scope 2). For other indirect GHG emissions generated in a reporting company’s value chain (Scope 3), we respectfully encourage the SEC to provide more targeted and flexible disclosures rather than the full Scope 3 framework proposed.
Vanguard has responded to the U.S. Department of the Treasury’s request for information on additional transparency in Treasury markets. In our comment letter, we advocate for transparency requirements that do not impair liquidity. We also call for strengthening reporting requirements for foreign banks and proprietary trading firms and for providing adequate safeguards to protect counterparty identities, holdings, and trading strategies.
Vanguard has submitted a comment letter responding to a Department of Labor (DOL) request for information on the implementation of several SECURE 2.0 provisions that address ERISA disclosures. The letter reiterates certain key positions that we shared with Congress during the legislative process, including our recommendation that the DOL not impose barriers to electronic delivery of plan communications beyond what is required by SECURE 2.0.
Vanguard has filed a comment letter in response to the Securities and Exchange Commission’s (SEC) proposal regarding conflicts of interest associated with the use of predictive data analytics by broker-dealers and investment advisors in investor interactions. Our comments emphasize the importance of prioritizing investor goals and interests in interactions with clients—not regulating technologies.
Vanguard submitted a comment letter on consultations from the Financial Stability Board (FSB) and International Organization of Securities Commissions (IOSCO) regarding liquidity risk management tools in open-end funds. The letter commends FSB’s and IOSCO’s recognition that fund liquidity practices should be flexible and based on a variety of factors. We also offer several suggestions for improving this effort.
Vanguard submitted a comment letter to the Securities and Exchange Commission (SEC) on four rule proposals to change equity market structure. The letter provides feedback on key aspects of the proposals, specifically the disclosure of broker-dealer execution quality, quoting and trading increments, the exchange access fee cap, and the handling of retail orders. One of our key recommendations is for the SEC to prioritize enhanced disclosure of broker-dealer execution quality by adopting the Rule 605 proposal, which would provide retail investors with the ability to compare execution quality and costs more easily among brokers.
Vanguard submitted a comment letter on the Securities and Exchange Commission’s proposed rule on liquidity risk management and swing pricing. The letter expresses a number of concerns with the proposal, including the costs to investors of its swing pricing requirements and the replacement of the liquidity rule’s current flexibility with a one-size-fits-all, prescriptive approach for all funds.
The Financial Industry Regulatory Authority (FINRA) has issued a proposal for a remote inspections pilot program that would replace a temporary program established at the beginning of the pandemic. In our comment letter filed with the U.S. Securities and Exchange Commission (SEC), Vanguard expressed support for FINRA’s pilot program, which would give FINRA members the option to conduct required inspections remotely for up to three years.