Comment Letters

Comments to SEC in Support of Legal Entity Identifier (LEI) Requirements

The FACT Coalition filed a comment on January 2, 2018 with the U.S. Securities and Exchange Commission (SEC) supporting the agency’s proposal to mandate the disclosure of Legal Entity Identifier (LEI) numbers by public companies and their subsidiaries.  The Coalition also urged requiring all public companies to obtain LEIs, ensuring that the LEIs are disclosed in a machine-readable format, and mandating that companies disclose all of their subsidiaries in their disclosures, rather than simply their “significant” subsidiaries.

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Letter to the IRS Supporting Treasury’s Corporate Inversion Regulations

The Financial Accountability and Corporate Transparency Coalition (FACT Coalition) sent a letter to the IRS in support of the Department of the Treasury’s Final and Temporary Regulations under Section 385 on the Treatment of Certain Interests in Corporations as Stock or Indebtedness. The full letter can be read below or downloaded here.

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Comments to GSA Urging Non-Proprietary, Open Identifier System in Procurement

The Financial Accountability and Corporate Transparency Coalition (FACT Coalition) submitted the below comments to the General Services Administration (GSA), in response to RFI #ID15170001, urging the agency to adopt a non-proprietary, open identifier system for use in federal procurement that includes the collection of information on the real people who own and control bidders of federal contracts and grants (also known as ‘beneficial owners’).

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