Advocacy
In addition to producing scholarly publications, I co-author responses to federal agency calls for comment on proposed rules. I believe that assisting the government with its rulemaking decisions is a core responsibility for researchers and offers a vital opportunity to advocate for change. Many of these responses are co-authored alongside law students, providing them with hands-on regulatory experience.
I am pleased to share that a public comment co-authored by Alyssa Boob and myself was officially cited by the Employee Benefits Security Administration (EBSA) of the U.S. Department of Labor. Our insights were referenced in the Regulatory Impact Analysis – Benefits for Participants – Improved Understanding of Plan Information accompanying footnote 66 of the 2026 proposed rule, “Electronic Disclosure by Group Health Plans under ERISA” (2 CFR Parts 2520 and 2560) acknowledging our contribution to the regulatory discourse.
Correspondence by Year
2026
- US Department of Treasury and IRS Request for Recommendations for Items to be Included in the IRS 2026-27 Priority Guidance Plan, Comments asking IRS to add to its Priority Plan the elimination of 401(k) plan vesting schedules with a goal toward the agency recommending Congress repeal 26 U.S.C. § 411(a)(2)(B) as it pertains to qualified 401(k) plans, May 27, 2026 (with Ariana Bignotti)
2025
- US Department of Treasury and IRS Request for Recommendations for Items to be Included in the IRS 2025-26 Priority Guidance Plan, Comments asking IRS to add to its Priority Plan the elimination of 401(k) plan vesting schedules with a goal toward the agency recommending Congress repeal 26 U.S.C. § 411(a)(2)(B) as it pertains to qualified 401(k) plans, May 28, 2025 (with Tim Azizkhan and Rebecca Hatton)
2024
- US Department of Treasury and IRS Request for Recommendations for Items to be Included in the IRS 2024-25 Priority Guidance Plan, Comments asking IRS to add to its Priority Plan the elimination of 401(k) plan vesting schedules with a goal toward the agency recommending Congress repeal 26 U.S.C. § 411(a)(2)(B) as it pertains to qualified 401(k) plans, May 30, 2024 (with Tim Azizkhan)
- US Department of Treasury’s, Department of Labor’s, and Pension Benefit Guaranty Corporation’s Request for Information—Secure 2.0 Section. 319—Effectiveness of Reporting and Disclosure Requirements, Comments outlining the need for clear, uniform, understandable 401(k) benefits disclosures in job postings and on company websites, Apr. 22, 2024 (with Alyssa Boob)
- US Department of Treasury’s Request for Information on Advancing Financial Inclusion, Comments outlining 401(k) vesting schedules exacerbate people’s ability to achieve financial well-being and health, Feb. 20, 2024 (with Ana Maria Matovic)
2022
- US Department of Labor FLSA Worker Classification Proposed Rule Response: Comments on US Department of Labor Worker Classification Proposed Rule for FLSA Purposes, Dec. 12, 2022 (with Taylor Haberle and Lauren Stahl)
2020
- NSAA Draft Model Whistleblower Award and Protection Act Response: Securities Scholars’ Comment Letter on Draft Model Whistleblower Award and Protection Act, June 29, 2020 (with Andrew C. Baker, Benjamin Edwards, and Andrew Jennings)
2019
- SEC Concept Release Response: Re: Concept Release on Harmonization of Securities Offering Exemptions; File Number S7-08-19 (with Robert Anderson, John Niel Conkle, and Sarah Zomaya)
