Advocacy
In addition to producing scholarly publications, I have co-authored responses to federal agency calls for comment of proposed rules. I believe that assisting the government with its rule-making decisions is our responsibility as researchers and affords us the opportunity to advocate for change. Many of my responses are co-authored with law students.
Correspondence by Year
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)
