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New Jersey Employer Penalty Threatens Jobs, Health Care Coverage and Economic Growth
WASHINGTON, Aug. 21 -- The National Retail Federation posted the following news release:
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New Jersey Employer Penalty Threatens Jobs, Health Care Coverage and Economic Growth
A coalition of employers filed a federal lawsuit today challenging New Jersey's recently enacted "Fair Share" law, which imposes a new penalty on employers that create jobs in New Jersey and makes it more difficult for them to provide health care coverage to their employees.
"This law amounts to a penalty on employers that create jobs, provide health care coverage and drive economic growth in New Jersey," National ... Show Full Article WASHINGTON, Aug. 21 -- The National Retail Federation posted the following news release: * * * New Jersey Employer Penalty Threatens Jobs, Health Care Coverage and Economic Growth A coalition of employers filed a federal lawsuit today challenging New Jersey's recently enacted "Fair Share" law, which imposes a new penalty on employers that create jobs in New Jersey and makes it more difficult for them to provide health care coverage to their employees. "This law amounts to a penalty on employers that create jobs, provide health care coverage and drive economic growth in New Jersey," NationalRetail Federation Executive Vice President of Government Relations David French said. "Rather than working with the businesses and organizations that employ millions of people and support communities across the state to find constructive ways to provide health care to New Jersey workers, lawmakers rushed forward with a mandate that ignores federal law, imposes new penalties on employers and makes New Jersey a more difficult place to do business."
Beyond imposing a costly new penalty on job creators, the law would force employers to redesign their health benefit plans to comply with state-imposed mandates. That requirement directly conflicts with the Employee Retirement Income Security Act of 1974, which Congress enacted to encourage employers to provide health care coverage under a uniform national framework. ERISA enables large employers to offer comprehensive, affordable coverage to employees across state lines without navigating a patchwork of conflicting state benefit mandates and reporting requirements. Allowing New Jersey's law to stand would undermine the national framework protecting employee benefits that has been in place for more than 50 years.
New Jersey's new employer penalty legislation was rushed through without meaningful stakeholder engagement. The result is a law that is unlawful, wholly unworkable and administratively burdensome on New Jersey's job creators.
The lawsuit was jointly filed in the U.S. District Court of New Jersey by NRF, the Restaurant Law Center, the International Franchise Association and the American Hotel and Lodging Association.
The plaintiffs are seeking declaratory and injunctive relief to prevent enforcement of the statute so they can continue to create jobs and provide meaningful health care coverage to thousands of New Jersey workers.
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About NRF
The National Retail Federation passionately advocates for the people, brands, policies and ideas that help retail succeed. From its headquarters in Washington, D.C., NRF empowers the industry that powers the economy. Retail is the nation's largest private-sector employer, contributing $5.3 trillion to annual GDP and supporting more than one in four U.S. jobs -- 55 million working Americans. For over a century, NRF has been a voice for every retailer and every retail job, educating, inspiring and communicating the powerful impact retail has on local communities and global economies. nrf.com
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Original text here: https://nrf.com/media-center/press-releases/new-jersey-employer-penalty-threatens-jobs-health-care-coverage-and-economic-growth
[Category: Business]
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New Jersey Employer Penalty Threatens Jobs, Health Care Coverage and Economic Growth
A coalition of employers filed a federal lawsuit today challenging New Jersey's recently enacted "Fair Share" law, which imposes a new penalty on employers that create jobs in New Jersey and makes it more difficult for them to provide health care coverage to their employees.
"This law amounts to a penalty on employers that create jobs, provide health care coverage and drive economic growth in New Jersey," National ... Show Full Article WASHINGTON, Aug. 21 -- The National Retail Federation posted the following news release: * * * New Jersey Employer Penalty Threatens Jobs, Health Care Coverage and Economic Growth A coalition of employers filed a federal lawsuit today challenging New Jersey's recently enacted "Fair Share" law, which imposes a new penalty on employers that create jobs in New Jersey and makes it more difficult for them to provide health care coverage to their employees. "This law amounts to a penalty on employers that create jobs, provide health care coverage and drive economic growth in New Jersey," NationalRetail Federation Executive Vice President of Government Relations David French said. "Rather than working with the businesses and organizations that employ millions of people and support communities across the state to find constructive ways to provide health care to New Jersey workers, lawmakers rushed forward with a mandate that ignores federal law, imposes new penalties on employers and makes New Jersey a more difficult place to do business."
Beyond imposing a costly new penalty on job creators, the law would force employers to redesign their health benefit plans to comply with state-imposed mandates. That requirement directly conflicts with the Employee Retirement Income Security Act of 1974, which Congress enacted to encourage employers to provide health care coverage under a uniform national framework. ERISA enables large employers to offer comprehensive, affordable coverage to employees across state lines without navigating a patchwork of conflicting state benefit mandates and reporting requirements. Allowing New Jersey's law to stand would undermine the national framework protecting employee benefits that has been in place for more than 50 years.
New Jersey's new employer penalty legislation was rushed through without meaningful stakeholder engagement. The result is a law that is unlawful, wholly unworkable and administratively burdensome on New Jersey's job creators.
The lawsuit was jointly filed in the U.S. District Court of New Jersey by NRF, the Restaurant Law Center, the International Franchise Association and the American Hotel and Lodging Association.
The plaintiffs are seeking declaratory and injunctive relief to prevent enforcement of the statute so they can continue to create jobs and provide meaningful health care coverage to thousands of New Jersey workers.
* * *
About NRF
The National Retail Federation passionately advocates for the people, brands, policies and ideas that help retail succeed. From its headquarters in Washington, D.C., NRF empowers the industry that powers the economy. Retail is the nation's largest private-sector employer, contributing $5.3 trillion to annual GDP and supporting more than one in four U.S. jobs -- 55 million working Americans. For over a century, NRF has been a voice for every retailer and every retail job, educating, inspiring and communicating the powerful impact retail has on local communities and global economies. nrf.com
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Original text here: https://nrf.com/media-center/press-releases/new-jersey-employer-penalty-threatens-jobs-health-care-coverage-and-economic-growth
[Category: Business]
Managed Funds Association Issues Letter to SEC Secretary Countryman
WASHINGTON, Aug. 21 (TNSletter) -- The Managed Funds Association issued the following letter to Securities and Exchange Commission Secretary Vanessa Countryman:
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Here is the text of the letter:
August 17, 2026
Ms. Vanessa Countryman
Secretary
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: MFA Comment Letter on the proposed rescission of the Trade-Through Rule and Locked and Crossed Markets Provision of Regulation NMS (File No. S7-2026-20; RIN 3235-AN50)
Dear Ms. Countryman:
MFA1 appreciates the opportunity to submit comments to the U.S. Securities ... Show Full Article WASHINGTON, Aug. 21 (TNSletter) -- The Managed Funds Association issued the following letter to Securities and Exchange Commission Secretary Vanessa Countryman: * * * Here is the text of the letter: August 17, 2026 Ms. Vanessa Countryman Secretary U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: MFA Comment Letter on the proposed rescission of the Trade-Through Rule and Locked and Crossed Markets Provision of Regulation NMS (File No. S7-2026-20; RIN 3235-AN50) Dear Ms. Countryman: MFA1 appreciates the opportunity to submit comments to the U.S. Securitiesand Exchange Commission (the "Commission" or "SEC") in response to the release proposing to rescind (a) the trade-through rule for NMS stocks, currently set forth in Rule 611 of Regulation NMS (the "TradeThrough Rule"); (b) Rule 610(e) of Regulation NMS, which requires self-regulatory organizations to establish, maintain, and enforce rules to avoid locked and crossed markets (the "Locked and Crossed Market Provision"); and (c) corresponding definitions from Rule 610 of Regulation NMS (collectively, the "Proposing Release" or the "Proposal").2
MFA supports the Commission's ongoing evaluation of equity market structure, including targeted efforts to address regulatory incentives that may contribute to unnecessary venue proliferation and associated market-wide costs. We are concerned, however, that the Proposal would significantly alter a market structure that currently delivers strong outcomes for institutional investors without adequately demonstrating that the benefits of wholesale recission would warrant the resulting risks. U.S. equity markets are among the deepest, most liquid, and most efficient markets in the world, with substantial competition, robust price transparency, and low transaction costs. Before undertaking changes of this magnitude, the Commission should carefully assess the anticipated benefits and costs of rescission, including whether any expected benefits justify the potential risks to market quality and investor outcomes, and whether more targeted alternatives could achieve the Commission's objectives with fewer adverse consequences.
While MFA appreciates the Commission's interest in reducing unnecessary complexity and reevaluating longstanding market structure requirements, we are concerned that rescinding Rules 611 and 610(e), together with the related definitions that support the current framework, could have significant unintended consequences. Rules 611 and 610(e) are deeply embedded in the regulatory architecture governing U.S. equity markets, and rescinding them would have consequences extending well beyond trade-throughs and locked and crossed markets. For nearly two decades, market participants have built trading systems, compliance programs, and market practices around these requirements, while numerous other Commission and SRO rules have developed in reliance on concepts such as protected quotations and the National Best Bid or Offer ("NBBO"). The Proposal does not adequately address how this broader framework would function following rescission, including the implications for best execution, displayed liquidity, intermarket connectivity, the composition and reliability of the NBBO, and the many regulatory requirements that depend upon it.
MFA therefore believes the Commission should not proceed with wholesale rescission without first addressing these interdependencies, conducting a more complete analysis of the potential consequences for investors and market quality, and meaningfully evaluating more targeted alternatives. Given the strong performance of U.S. equity markets under the existing framework, fundamental changes to that framework should be supported by a clear demonstration that they will improve, rather than risk degrading, market quality and investor outcomes.
I. Background
The Commission adopted the Trade-Through Rule and other provisions of Regulation NMS in 2005 to promote both competition among market centers and competition among individual orders.3 Regulation NMS recognized the importance of limit orders in the price-setting process, finding that "strengthened protection of displayed limit orders would help reward market participants for displaying their trading interest and thereby promote fairer and more vigorous competition among orders seeking to supply liquidity."4 This framework allows displayed quotations to support pre-trade price discovery by contributing to a deep and liquid NBBO. Indeed, by connecting markets for automated quotations, Regulation NMS not only narrowed displayed spreads, but also assured the execution of the displayed orders that contribute to, if not help set, the NBBO. By encouraging displayed liquidity and a robust NBBO, Regulation NMS and the Trade-Through Rule set a strong benchmark against which to evaluate execution quality.5
The result of such framework is an equity market that is the envy of the world, characterized by ample liquidity, depth, and pre-trade transparency. Both retail and institutional orders receive high-quality executions in a market characterized by vigorous competition among trading centers. By all accounts, the U.S. equities markets work extremely well; orders of a range of sizes can be executed promptly, often with price improvement, and at relatively small execution costs.6
These outcomes should not be overlooked when evaluating the Proposal. The current market structure supports high levels of displayed liquidity, substantial competition among trading venues, and execution quality that benefits investors across a wide range of order sizes and investment strategies. Any assessment of potential reforms should begin with recognition that the existing framework has generated meaningful benefits for investors and issuers.
We agree that the U.S. equity markets have become more complex since the adoption of Regulation NMS and the Trade-Through Rule. As the Proposing Release recounts, there has been an increase in the number of order types and exchanges, thereby contributing to market fragmentation.7 The increase in the number of markets, in turn, contributes to the scope and amount of market data to which market participants subscribe, thereby increasing costs for such data.8 The question is, however, whether 611 is the primary driver of these developments. For example, other features of the current market structure, including the allocation of SIP revenues and the economics of market data and connectivity, create more direct economic incentives for venue proliferation and its associated costs.
Accordingly, the Commission should consider whether these costs have been sufficiently analyzed, whether Rule 611 is their principal cause, and whether they warrant significant changes to a well-functioning marketplace without more rigorous analysis and consideration of alternatives short of full rescission. For the reasons set forth below, MFA does not believe the Commission should proceed with the Proposal as currently formulated. Instead, the Commission should undertake additional analysis and more fully consider targeted alternatives that could address its concerns while preserving the benefits of the existing framework.
II. Discussion
A. The Existing Framework Continues to Provide Significant Benefits to Investors and Markets
MFA believes that the Trade-Through Rule provides important benefits to investors and the market by encouraging market participants to display competitively priced trading interest. By generally preventing a protected quotation from being bypassed by an inferior-priced execution, Rule 611 increases the likelihood that an investor displaying the best price will receive an execution. This protection creates an incentive to display liquidity publicly and contributes to deeper markets and greater competition among orders.
Displayed liquidity, in turn, plays an important role in pre-trade price discovery and price transparency.9 Displayed limit orders and other protected quotations contribute to the NBBO, allowing market participants to better determine the prevailing market price for a security and providing a transparent benchmark against which institutional and other investors can evaluate the quality of their executions. These benefits are particularly important to institutional investors, which rely on reliable public prices both when making investment and trading decisions and when evaluating the performance of brokers responsible for executing their orders.
MFA recognizes that the existing framework imposes costs, including costs associated with accessing liquidity across a growing number of trading venues. Those costs should be weighed against the benefits that Rule 611 provides through displayed liquidity, price discovery, execution quality, and competition among orders. Importantly, however, Rule 611 is not the only driver of these costs. Other features of the current market structure, including the allocation of SIP revenues and the economics of market data and connectivity, create independent incentives for the creation and continued operation of low-volume venues. The Proposal does not address these incentives, raising questions about whether rescinding Rule 611 would materially reduce the costs the Commission identifies while potentially sacrificing important benefits of the existing framework.
B. Additional Analysis Would Better Inform Changes to a Well-Functioning Market Structure
In MFA's view, the Commission needs to conduct more detailed analysis to support its proposed approach. MFA applauds certain of the efforts that the Commission has made to date, such as holding numerous roundtables on the Trade-Through Rule and other aspects of Regulation NMS, soliciting viewpoints and information from a wide range of market participants.10 Following this broad-based outreach and collection of analysis and viewpoints, however, the Commission did not sufficiently marshal the data provided or otherwise available to it to support rescinding the Trade-Through Rule.
Indeed, much of the Commission's approach, including in the economic analysis section of the Proposing Release, would benefit from additional support, as several key statements are framed in qualified or predictive terms rather than grounded in available data. For example, in support of its argument that fragmentation impacts the execution quality of large and institutional orders, the Commission states that the dispersion of liquidity resulting from fragmentation "can make institutional trading intentions easier to detect, which can increase slippage and hurt the overall execution quality of the parent order."11 In support of the statement, the Commission references Section VI.B.2.c of the Proposing Release, which itself lacks authority or analysis to support the arguments presented therein. For example, the Commission offers (without footnote or other support) that "Rule 611 may increase information leakage and the slippage faced by institutional investor parent orders because routing constraints under Rule 611 may reveal trading intentions more quickly or broadly than institutional investors would prefer, thereby affecting the overall execution quality for large orders."12 The balance of this section of the Proposing Release provides similar speculation, for example, that Rule 611 "may contribute" to price slippage because "child order executions may help alert liquidity providers to the presence of a larger parent order."13
MFA, whose members regularly place institutional-sized orders, acknowledges that the Trade-Through Rule might affect the execution overall of institutional orders. But institutional investors have for years refined their execution techniques to reduce the likelihood and impact of such effects to a point where they do outweigh other benefits of the rule. Accordingly, MFA supports the Commission engaging in specific analysis on this issue, whether from existing data or by conducting a pilot program comparing execution quality of securities in trade-through and non-trade through environments. But before the Commission makes changes of this significance to established equity market structure, we respectfully suggest that more analysis is warranted.
C. The Commission Should More Meaningfully Consider Reasonable Alternatives
The Proposing Release contains a section identifying reasonable alternatives to rescinding the Trade-Through Rule and the Locked and Crossed Market Prohibition.14 That section lists three alternatives: adopting a volume threshold for a venue to earn protected quote status, adding an additional trade-through exception for large trades, and rescinding the prohibition only for locked markets but not crossed markets. The Proposing Release devotes relatively limited discussion to these three alternatives and provides only limited supporting analysis--a level of examination that, in MFA's view, does not fully reflect their potential to address the Commission's stated concerns.
Because the current market structure generally produces favorable outcomes for investors, incremental reforms should be evaluated carefully before foundational market protections are removed. Thus, MFA believes that the Commission should meaningfully evaluate less drastic alternatives before fully rescinding the Trade-Through Rule and/or the Locked and Crossed Markets Prohibition. For example, if the Commission "believe[s] that both the benefits and costs of [the volume threshold for protected quotes] alternative would be lower than those of the Proposal"15, the Commission should substantiate its belief with objective analysis that accounts for the full cost of complying with additional conforming rule amendments that would be required if Rule 611 and Rule 610(e) were repealed or amended, as compared with the introduction of a narrow exception for low-volume exchanges. Similarly, even if "market participants would not experience most of the costs and benefits discussed in the Proposal"16 with a large trade exception, the Commission should evaluate critically whether this alternative would provide a meaningful benefit for market participants generally at a fraction of the cost. In short, the Commission should evaluate each of the alternatives in a comprehensive manner to determine whether they might sufficiently address the stated concerns of market fragmentation, exchange proliferation, and increased market complexity. Moreover, any of the stated alternatives might be sufficient to allow market forces operating under such alternative conditions to develop competitively and adequately shape equity market structure.
D. The Commission Should Further Evaluate the Proposal's Implications for the Broader Regulatory Framework
Rule 611 does not operate in isolation. It forms part of a broader regulatory framework that relies on the concepts of protected quotations and the NBBO to establish objective benchmarks for order handling, execution quality, short-sale restrictions, market data dissemination, and numerous other regulatory obligations. While the Proposing Release recognizes that rescinding the Trade-Through Rule may have implications for other aspects of market structure, it provides relatively little analysis of how those interdependencies would operate following rescission. Changes to these foundational components will inevitably require adjustments to trading practices, systems, compliance controls, execution analysis, and market infrastructure. Understanding those practical consequences should be an important part of the Commission's evaluation. Importantly, the Proposal rescinds Rule 611, together with the related definitions of "automated quotation" and "manual quotation," without explaining what standards, if any, would continue to govern whether a displayed quotation should contribute to the NBBO. As a result, quotations that are subject to asymmetric access delays17, limited accessibility, or other execution constraints could nevertheless establish the national best bid or offer. Similarly, if market participants are no longer expected to maintain connectivity to every trading venue, quotations displayed on venues that many firms do not access could continue to define the NBBO notwithstanding their practical inaccessibility. The Proposal does not evaluate how the inclusion of such quotations would affect displayed liquidity and the reliability of the NBBO as the benchmark against which execution quality and investor transaction costs are measured, nor does it assess the implications for the many Commission rules that rely upon the NBBO as an objective regulatory reference point.18
These questions extend well beyond Rule 611 itself. If the characteristics of quotations eligible to establish the NBBO were to change, the Commission should evaluate the resulting implications for Regulation SHO, best execution, Rule 605, Rule 606, the Vendor Display Rule, and the many other provisions of the federal securities laws and SRO rules that rely upon the NBBO as an objective regulatory benchmark.
Similar uncertainty exists regarding the duty of best execution. The Commission states that best execution obligations would continue to require brokers to use reasonable diligence to obtain the most favorable terms reasonably available and that Rule 611 is no longer necessary as a backstop to those obligations because today's markets are highly automated and interconnected. Those statements, however, fail to give market participants concrete guidance for a post-recission market structure. If market participants are expected to use existing connectivity and automation to access superior quotations displayed on other venues, rescission may simply relocate many of the practical effects of Rule 611 into the best execution framework. Conversely, if broker-dealers will have greater discretion to disregard quotations displayed on certain venues, the Commission should explain how best execution will be evaluated.
Indeed, given the transformation of market structure contemplated by the Proposal, FINRA has requested input on ways to update its best execution guidance.19 As the Trade-Through Rule, the Locked and Crossed Markets Provision, and the duty of best execution are all deeply interconnected, the Commission should take into account and evaluate comments provided to FINRA's solicitation before taking any action on the Proposal. Further, if the Commission were to proceed to rescind the Trade-Through Rule, it should provide detailed guidance on best execution obligations in a non-trade through environment with less market connectivity, with specific reference to comments provided to FINRA or any separate best execution commentary the Commission might solicit. More broadly, the Proposal raises questions regarding numerous Commission rules and market structure requirements that currently rely upon protected quotations or the NBBO, including Rules 605 and 606, the Vendor Display Rule, Regulation M, Rule 10b-18, consolidated market data requirements, and other provisions that incorporate the NBBO as an objective regulatory benchmark. While the Commission need not resolve every downstream issue before acting, these interactions warrant substantially greater consideration than the Proposal provides, both substantively and in its economic analysis. A clearer explanation of how these interconnected requirements would function following rescission would materially improve the Commission's assessment of the Proposal, give the Commission a superior accounting of all foreseeable costs of implementing the Proposal, and provide greater certainty to market participants.
III. Conclusion
U.S. equity markets currently deliver significant benefits to both retail and institutional investors through deep liquidity, strong competition, efficient execution, and robust price transparency. Given the significance of the proposed changes and the unresolved questions regarding their effects on market quality, investors, and the broader regulatory framework, MFA believes further analysis is warranted before fundamentally altering the existing market structure. For that reason, MFA urges the Commission not to proceed with the Proposal as currently formulated and instead to undertake additional analysis, address the implications for the broader regulatory framework, and more fully evaluate targeted alternatives that could achieve the Commission's objectives while preserving the important benefits of the existing market structure.
Finally, if the Commission were to adopt the Proposal notwithstanding the reasonable concerns of MFA and other commenters, we urge the Commission to delay the effective date of any rescission to allow market participants sufficient time to reprogram order handling and order execution systems and engage in sufficient testing. We would recommend a pre-effective implementation period of no less than 12 months. As the Commission can appreciate, particularly in today's increasingly automated markets, market participants have implemented significant technology and trading infrastructure to adapt to the current market structure. If there were to be a change to such market structure as significant as rescission of the Trade-Through Rule and the increased possibility of locked and crossed markets, significant programming will be required both to roll back programming implemented since the adoption of Regulation NMS and to address any other changes resulting from any adoption of the Proposal.
[The remainder of the page is left intentionally blank.]
* * * * *
MFA appreciates both the opportunity to comment on the Proposing Release and the
Commission's interest in evaluating current equity market structure and the attendant costs to market participants thereunder. To the extent helpful, we are happy to discuss our comments in greater detail with members of the Commission staff. Please do not hesitate to contact Matthew Daigler (mdaigler@mfaalts.org) or the undersigned (jhan@mfaalts.org) with any questions regarding this letter.
Sincerely,
Jennifer W. Han, Chief Legal Officer & Head of Global Regulatory Affairs, MFA
cc: The Hon. Paul S. Atkins, Chairman
The Hon. Hester M. Peirce, Commissioner
The Hon. Mark T. Uyeda, Commissioner
Jamie Selway, Director, Division of Trading and Markets
Joshua White, Chief Economist, Division of Economic and Risk Analysis
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Original text and footnotes here: https://www.mfaalts.org/wp-content/uploads/2026/08/MFA-Comment-Letter-on-Rule-611-Proposal-As-submitted-8.17.26.pdf
News Release here: https://www.mfaalts.org/press-releases/mfa-urges-the-sec-to-conduct-further-analysis-before-changing-key-equity-market-rules/
[Category: Financial Services]
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Here is the text of the letter:
August 17, 2026
Ms. Vanessa Countryman
Secretary
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: MFA Comment Letter on the proposed rescission of the Trade-Through Rule and Locked and Crossed Markets Provision of Regulation NMS (File No. S7-2026-20; RIN 3235-AN50)
Dear Ms. Countryman:
MFA1 appreciates the opportunity to submit comments to the U.S. Securities ... Show Full Article WASHINGTON, Aug. 21 (TNSletter) -- The Managed Funds Association issued the following letter to Securities and Exchange Commission Secretary Vanessa Countryman: * * * Here is the text of the letter: August 17, 2026 Ms. Vanessa Countryman Secretary U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: MFA Comment Letter on the proposed rescission of the Trade-Through Rule and Locked and Crossed Markets Provision of Regulation NMS (File No. S7-2026-20; RIN 3235-AN50) Dear Ms. Countryman: MFA1 appreciates the opportunity to submit comments to the U.S. Securitiesand Exchange Commission (the "Commission" or "SEC") in response to the release proposing to rescind (a) the trade-through rule for NMS stocks, currently set forth in Rule 611 of Regulation NMS (the "TradeThrough Rule"); (b) Rule 610(e) of Regulation NMS, which requires self-regulatory organizations to establish, maintain, and enforce rules to avoid locked and crossed markets (the "Locked and Crossed Market Provision"); and (c) corresponding definitions from Rule 610 of Regulation NMS (collectively, the "Proposing Release" or the "Proposal").2
MFA supports the Commission's ongoing evaluation of equity market structure, including targeted efforts to address regulatory incentives that may contribute to unnecessary venue proliferation and associated market-wide costs. We are concerned, however, that the Proposal would significantly alter a market structure that currently delivers strong outcomes for institutional investors without adequately demonstrating that the benefits of wholesale recission would warrant the resulting risks. U.S. equity markets are among the deepest, most liquid, and most efficient markets in the world, with substantial competition, robust price transparency, and low transaction costs. Before undertaking changes of this magnitude, the Commission should carefully assess the anticipated benefits and costs of rescission, including whether any expected benefits justify the potential risks to market quality and investor outcomes, and whether more targeted alternatives could achieve the Commission's objectives with fewer adverse consequences.
While MFA appreciates the Commission's interest in reducing unnecessary complexity and reevaluating longstanding market structure requirements, we are concerned that rescinding Rules 611 and 610(e), together with the related definitions that support the current framework, could have significant unintended consequences. Rules 611 and 610(e) are deeply embedded in the regulatory architecture governing U.S. equity markets, and rescinding them would have consequences extending well beyond trade-throughs and locked and crossed markets. For nearly two decades, market participants have built trading systems, compliance programs, and market practices around these requirements, while numerous other Commission and SRO rules have developed in reliance on concepts such as protected quotations and the National Best Bid or Offer ("NBBO"). The Proposal does not adequately address how this broader framework would function following rescission, including the implications for best execution, displayed liquidity, intermarket connectivity, the composition and reliability of the NBBO, and the many regulatory requirements that depend upon it.
MFA therefore believes the Commission should not proceed with wholesale rescission without first addressing these interdependencies, conducting a more complete analysis of the potential consequences for investors and market quality, and meaningfully evaluating more targeted alternatives. Given the strong performance of U.S. equity markets under the existing framework, fundamental changes to that framework should be supported by a clear demonstration that they will improve, rather than risk degrading, market quality and investor outcomes.
I. Background
The Commission adopted the Trade-Through Rule and other provisions of Regulation NMS in 2005 to promote both competition among market centers and competition among individual orders.3 Regulation NMS recognized the importance of limit orders in the price-setting process, finding that "strengthened protection of displayed limit orders would help reward market participants for displaying their trading interest and thereby promote fairer and more vigorous competition among orders seeking to supply liquidity."4 This framework allows displayed quotations to support pre-trade price discovery by contributing to a deep and liquid NBBO. Indeed, by connecting markets for automated quotations, Regulation NMS not only narrowed displayed spreads, but also assured the execution of the displayed orders that contribute to, if not help set, the NBBO. By encouraging displayed liquidity and a robust NBBO, Regulation NMS and the Trade-Through Rule set a strong benchmark against which to evaluate execution quality.5
The result of such framework is an equity market that is the envy of the world, characterized by ample liquidity, depth, and pre-trade transparency. Both retail and institutional orders receive high-quality executions in a market characterized by vigorous competition among trading centers. By all accounts, the U.S. equities markets work extremely well; orders of a range of sizes can be executed promptly, often with price improvement, and at relatively small execution costs.6
These outcomes should not be overlooked when evaluating the Proposal. The current market structure supports high levels of displayed liquidity, substantial competition among trading venues, and execution quality that benefits investors across a wide range of order sizes and investment strategies. Any assessment of potential reforms should begin with recognition that the existing framework has generated meaningful benefits for investors and issuers.
We agree that the U.S. equity markets have become more complex since the adoption of Regulation NMS and the Trade-Through Rule. As the Proposing Release recounts, there has been an increase in the number of order types and exchanges, thereby contributing to market fragmentation.7 The increase in the number of markets, in turn, contributes to the scope and amount of market data to which market participants subscribe, thereby increasing costs for such data.8 The question is, however, whether 611 is the primary driver of these developments. For example, other features of the current market structure, including the allocation of SIP revenues and the economics of market data and connectivity, create more direct economic incentives for venue proliferation and its associated costs.
Accordingly, the Commission should consider whether these costs have been sufficiently analyzed, whether Rule 611 is their principal cause, and whether they warrant significant changes to a well-functioning marketplace without more rigorous analysis and consideration of alternatives short of full rescission. For the reasons set forth below, MFA does not believe the Commission should proceed with the Proposal as currently formulated. Instead, the Commission should undertake additional analysis and more fully consider targeted alternatives that could address its concerns while preserving the benefits of the existing framework.
II. Discussion
A. The Existing Framework Continues to Provide Significant Benefits to Investors and Markets
MFA believes that the Trade-Through Rule provides important benefits to investors and the market by encouraging market participants to display competitively priced trading interest. By generally preventing a protected quotation from being bypassed by an inferior-priced execution, Rule 611 increases the likelihood that an investor displaying the best price will receive an execution. This protection creates an incentive to display liquidity publicly and contributes to deeper markets and greater competition among orders.
Displayed liquidity, in turn, plays an important role in pre-trade price discovery and price transparency.9 Displayed limit orders and other protected quotations contribute to the NBBO, allowing market participants to better determine the prevailing market price for a security and providing a transparent benchmark against which institutional and other investors can evaluate the quality of their executions. These benefits are particularly important to institutional investors, which rely on reliable public prices both when making investment and trading decisions and when evaluating the performance of brokers responsible for executing their orders.
MFA recognizes that the existing framework imposes costs, including costs associated with accessing liquidity across a growing number of trading venues. Those costs should be weighed against the benefits that Rule 611 provides through displayed liquidity, price discovery, execution quality, and competition among orders. Importantly, however, Rule 611 is not the only driver of these costs. Other features of the current market structure, including the allocation of SIP revenues and the economics of market data and connectivity, create independent incentives for the creation and continued operation of low-volume venues. The Proposal does not address these incentives, raising questions about whether rescinding Rule 611 would materially reduce the costs the Commission identifies while potentially sacrificing important benefits of the existing framework.
B. Additional Analysis Would Better Inform Changes to a Well-Functioning Market Structure
In MFA's view, the Commission needs to conduct more detailed analysis to support its proposed approach. MFA applauds certain of the efforts that the Commission has made to date, such as holding numerous roundtables on the Trade-Through Rule and other aspects of Regulation NMS, soliciting viewpoints and information from a wide range of market participants.10 Following this broad-based outreach and collection of analysis and viewpoints, however, the Commission did not sufficiently marshal the data provided or otherwise available to it to support rescinding the Trade-Through Rule.
Indeed, much of the Commission's approach, including in the economic analysis section of the Proposing Release, would benefit from additional support, as several key statements are framed in qualified or predictive terms rather than grounded in available data. For example, in support of its argument that fragmentation impacts the execution quality of large and institutional orders, the Commission states that the dispersion of liquidity resulting from fragmentation "can make institutional trading intentions easier to detect, which can increase slippage and hurt the overall execution quality of the parent order."11 In support of the statement, the Commission references Section VI.B.2.c of the Proposing Release, which itself lacks authority or analysis to support the arguments presented therein. For example, the Commission offers (without footnote or other support) that "Rule 611 may increase information leakage and the slippage faced by institutional investor parent orders because routing constraints under Rule 611 may reveal trading intentions more quickly or broadly than institutional investors would prefer, thereby affecting the overall execution quality for large orders."12 The balance of this section of the Proposing Release provides similar speculation, for example, that Rule 611 "may contribute" to price slippage because "child order executions may help alert liquidity providers to the presence of a larger parent order."13
MFA, whose members regularly place institutional-sized orders, acknowledges that the Trade-Through Rule might affect the execution overall of institutional orders. But institutional investors have for years refined their execution techniques to reduce the likelihood and impact of such effects to a point where they do outweigh other benefits of the rule. Accordingly, MFA supports the Commission engaging in specific analysis on this issue, whether from existing data or by conducting a pilot program comparing execution quality of securities in trade-through and non-trade through environments. But before the Commission makes changes of this significance to established equity market structure, we respectfully suggest that more analysis is warranted.
C. The Commission Should More Meaningfully Consider Reasonable Alternatives
The Proposing Release contains a section identifying reasonable alternatives to rescinding the Trade-Through Rule and the Locked and Crossed Market Prohibition.14 That section lists three alternatives: adopting a volume threshold for a venue to earn protected quote status, adding an additional trade-through exception for large trades, and rescinding the prohibition only for locked markets but not crossed markets. The Proposing Release devotes relatively limited discussion to these three alternatives and provides only limited supporting analysis--a level of examination that, in MFA's view, does not fully reflect their potential to address the Commission's stated concerns.
Because the current market structure generally produces favorable outcomes for investors, incremental reforms should be evaluated carefully before foundational market protections are removed. Thus, MFA believes that the Commission should meaningfully evaluate less drastic alternatives before fully rescinding the Trade-Through Rule and/or the Locked and Crossed Markets Prohibition. For example, if the Commission "believe[s] that both the benefits and costs of [the volume threshold for protected quotes] alternative would be lower than those of the Proposal"15, the Commission should substantiate its belief with objective analysis that accounts for the full cost of complying with additional conforming rule amendments that would be required if Rule 611 and Rule 610(e) were repealed or amended, as compared with the introduction of a narrow exception for low-volume exchanges. Similarly, even if "market participants would not experience most of the costs and benefits discussed in the Proposal"16 with a large trade exception, the Commission should evaluate critically whether this alternative would provide a meaningful benefit for market participants generally at a fraction of the cost. In short, the Commission should evaluate each of the alternatives in a comprehensive manner to determine whether they might sufficiently address the stated concerns of market fragmentation, exchange proliferation, and increased market complexity. Moreover, any of the stated alternatives might be sufficient to allow market forces operating under such alternative conditions to develop competitively and adequately shape equity market structure.
D. The Commission Should Further Evaluate the Proposal's Implications for the Broader Regulatory Framework
Rule 611 does not operate in isolation. It forms part of a broader regulatory framework that relies on the concepts of protected quotations and the NBBO to establish objective benchmarks for order handling, execution quality, short-sale restrictions, market data dissemination, and numerous other regulatory obligations. While the Proposing Release recognizes that rescinding the Trade-Through Rule may have implications for other aspects of market structure, it provides relatively little analysis of how those interdependencies would operate following rescission. Changes to these foundational components will inevitably require adjustments to trading practices, systems, compliance controls, execution analysis, and market infrastructure. Understanding those practical consequences should be an important part of the Commission's evaluation. Importantly, the Proposal rescinds Rule 611, together with the related definitions of "automated quotation" and "manual quotation," without explaining what standards, if any, would continue to govern whether a displayed quotation should contribute to the NBBO. As a result, quotations that are subject to asymmetric access delays17, limited accessibility, or other execution constraints could nevertheless establish the national best bid or offer. Similarly, if market participants are no longer expected to maintain connectivity to every trading venue, quotations displayed on venues that many firms do not access could continue to define the NBBO notwithstanding their practical inaccessibility. The Proposal does not evaluate how the inclusion of such quotations would affect displayed liquidity and the reliability of the NBBO as the benchmark against which execution quality and investor transaction costs are measured, nor does it assess the implications for the many Commission rules that rely upon the NBBO as an objective regulatory reference point.18
These questions extend well beyond Rule 611 itself. If the characteristics of quotations eligible to establish the NBBO were to change, the Commission should evaluate the resulting implications for Regulation SHO, best execution, Rule 605, Rule 606, the Vendor Display Rule, and the many other provisions of the federal securities laws and SRO rules that rely upon the NBBO as an objective regulatory benchmark.
Similar uncertainty exists regarding the duty of best execution. The Commission states that best execution obligations would continue to require brokers to use reasonable diligence to obtain the most favorable terms reasonably available and that Rule 611 is no longer necessary as a backstop to those obligations because today's markets are highly automated and interconnected. Those statements, however, fail to give market participants concrete guidance for a post-recission market structure. If market participants are expected to use existing connectivity and automation to access superior quotations displayed on other venues, rescission may simply relocate many of the practical effects of Rule 611 into the best execution framework. Conversely, if broker-dealers will have greater discretion to disregard quotations displayed on certain venues, the Commission should explain how best execution will be evaluated.
Indeed, given the transformation of market structure contemplated by the Proposal, FINRA has requested input on ways to update its best execution guidance.19 As the Trade-Through Rule, the Locked and Crossed Markets Provision, and the duty of best execution are all deeply interconnected, the Commission should take into account and evaluate comments provided to FINRA's solicitation before taking any action on the Proposal. Further, if the Commission were to proceed to rescind the Trade-Through Rule, it should provide detailed guidance on best execution obligations in a non-trade through environment with less market connectivity, with specific reference to comments provided to FINRA or any separate best execution commentary the Commission might solicit. More broadly, the Proposal raises questions regarding numerous Commission rules and market structure requirements that currently rely upon protected quotations or the NBBO, including Rules 605 and 606, the Vendor Display Rule, Regulation M, Rule 10b-18, consolidated market data requirements, and other provisions that incorporate the NBBO as an objective regulatory benchmark. While the Commission need not resolve every downstream issue before acting, these interactions warrant substantially greater consideration than the Proposal provides, both substantively and in its economic analysis. A clearer explanation of how these interconnected requirements would function following rescission would materially improve the Commission's assessment of the Proposal, give the Commission a superior accounting of all foreseeable costs of implementing the Proposal, and provide greater certainty to market participants.
III. Conclusion
U.S. equity markets currently deliver significant benefits to both retail and institutional investors through deep liquidity, strong competition, efficient execution, and robust price transparency. Given the significance of the proposed changes and the unresolved questions regarding their effects on market quality, investors, and the broader regulatory framework, MFA believes further analysis is warranted before fundamentally altering the existing market structure. For that reason, MFA urges the Commission not to proceed with the Proposal as currently formulated and instead to undertake additional analysis, address the implications for the broader regulatory framework, and more fully evaluate targeted alternatives that could achieve the Commission's objectives while preserving the important benefits of the existing market structure.
Finally, if the Commission were to adopt the Proposal notwithstanding the reasonable concerns of MFA and other commenters, we urge the Commission to delay the effective date of any rescission to allow market participants sufficient time to reprogram order handling and order execution systems and engage in sufficient testing. We would recommend a pre-effective implementation period of no less than 12 months. As the Commission can appreciate, particularly in today's increasingly automated markets, market participants have implemented significant technology and trading infrastructure to adapt to the current market structure. If there were to be a change to such market structure as significant as rescission of the Trade-Through Rule and the increased possibility of locked and crossed markets, significant programming will be required both to roll back programming implemented since the adoption of Regulation NMS and to address any other changes resulting from any adoption of the Proposal.
[The remainder of the page is left intentionally blank.]
* * * * *
MFA appreciates both the opportunity to comment on the Proposing Release and the
Commission's interest in evaluating current equity market structure and the attendant costs to market participants thereunder. To the extent helpful, we are happy to discuss our comments in greater detail with members of the Commission staff. Please do not hesitate to contact Matthew Daigler (mdaigler@mfaalts.org) or the undersigned (jhan@mfaalts.org) with any questions regarding this letter.
Sincerely,
Jennifer W. Han, Chief Legal Officer & Head of Global Regulatory Affairs, MFA
cc: The Hon. Paul S. Atkins, Chairman
The Hon. Hester M. Peirce, Commissioner
The Hon. Mark T. Uyeda, Commissioner
Jamie Selway, Director, Division of Trading and Markets
Joshua White, Chief Economist, Division of Economic and Risk Analysis
* * *
Original text and footnotes here: https://www.mfaalts.org/wp-content/uploads/2026/08/MFA-Comment-Letter-on-Rule-611-Proposal-As-submitted-8.17.26.pdf
News Release here: https://www.mfaalts.org/press-releases/mfa-urges-the-sec-to-conduct-further-analysis-before-changing-key-equity-market-rules/
[Category: Financial Services]
Managed Funds Association Issues Letter to Rep. Waters
WASHINGTON, Aug. 21 (TNSletter) -- The Managed Funds Association issued the following letter to Rep. Maxine Waters, D-California, ranking member of the House Financial Services Committee:
* * *
Here is the text of the letter:
August 14, 2026
The Honorable Maxine Waters
Ranking Member
Committee on Financial Services
U.S. House of Representatives
Washington, DC 20515
Re: Request for Information on AI Risks and Modernization in Financial Services
Dear Ranking Member Waters:
Managed Funds Association1 ("MFA") appreciates the opportunity to submit comments in response to the Ranking Member's ... Show Full Article WASHINGTON, Aug. 21 (TNSletter) -- The Managed Funds Association issued the following letter to Rep. Maxine Waters, D-California, ranking member of the House Financial Services Committee: * * * Here is the text of the letter: August 14, 2026 The Honorable Maxine Waters Ranking Member Committee on Financial Services U.S. House of Representatives Washington, DC 20515 Re: Request for Information on AI Risks and Modernization in Financial Services Dear Ranking Member Waters: Managed Funds Association1 ("MFA") appreciates the opportunity to submit comments in response to the Ranking Member'sRequest for Information ("RFI") regarding artificial intelligence ("AI") risks and modernization in financial services. MFA recognizes the important role policymakers play in better understanding this rapidly evolving technology, how it impacts markets and investors, and whether regulatory changes are warranted. MFA is committed to being a resource to policymakers globally as this important work moves forward.
Attached are MFA's prior submissions to the U.S. Department of the Treasury and the Financial Stability Board regarding AI. These submissions address many of the broader policy considerations raised in the RFI and underscore the importance of maintaining a proportionate, technology-neutral, and principles-based approach to AI oversight.
High-Level Considerations Regarding AI
As policymakers consider the role of AI in financial markets, several considerations should guide the discussion:
* First, existing securities laws already provide a robust framework governing the use of AI by investment advisers. Investment advisers remain responsible for complying with their legal and regulatory obligations regardless of whether they perform a function through employees, traditional software, quantitative models, algorithms, or AI-enabled tools.
* Second, AI technologies and use cases continue to evolve rapidly. Because AI is being deployed differently across firms and functions, policymakers should avoid prescriptive or technology-specific requirements that may quickly become outdated, discourage beneficial innovation, or impose unnecessary compliance burdens without corresponding investor protection benefits.
* Third, AI should be viewed mainly as a technological tool rather than a distinct regulated activity. Alternative asset managers use a wide range of technologies to support investment research, portfolio management, trading, compliance, risk management, cybersecurity, operations, and investor communications. The federal securities laws generally do not regulate particular technologies. Instead, they establish principles-based obligations governing how regulated activities are conducted and the outcomes firms must achieve.
For these reasons, policymakers should continue to evaluate AI through a technology-neutral framework focused on activities, risks, and outcomes rather than through rules directed at a specific technology.
Existing Regulatory Framework Already Governs the Use of AI
The Investment Advisers Act of 1940 and the SEC's rules thereunder already provide a comprehensive framework governing how private fund advisers develop, oversee, and deploy AI. Investment advisers are fiduciaries and must act in the best interests of their clients and investors. The SEC has recently reiterated that existing fiduciary standards apply to the use of AI, and that AI-related compliance remains an examination priority.
* Existing Fiduciary Requirements - Existing fiduciary obligations require advisers to exercise appropriate oversight and judgment when using AI, just as they do when using other technologies or third-party service providers. These principles-based standards are particularly well-suited to rapidly evolving technologies because they allow firms to tailor governance, testing, monitoring, and controls to the specific use cases and risks presented.
* Existing Regulatory Requirements - Beyond fiduciary obligations, advisers are subject to a broad range of existing regulatory requirements that are relevant to AI-enabled activities. These include requirements relating to compliance programs, books and records, disclosures, best execution, trading controls, vendor oversight, and other supervisory and governance obligations. These requirements provide regulators with significant visibility into adviser operations and create clear accountability for firm conduct.
This approach is consistent with how securities regulation has historically accommodated technological innovation. Over time, advisers have adopted increasingly sophisticated software, quantitative models, algorithmic systems, cloud computing technologies, cybersecurity tools, and operational platforms. Regulators generally have not created separate regulatory regimes for each new technology. Instead, existing principles-based obligations have applied regardless of the specific tools firms choose to use.
AI Use Cases Continue to Evolve
AI is being used across a wide range of business functions, including investment research, operational efficiency, compliance monitoring, cybersecurity, data analysis, trade support, and risk management. The scope and sophistication of these applications continue to develop rapidly.
The diversity of AI use cases underscores the importance of maintaining a flexible, principles-based regulatory approach. Different applications present different benefits, limitations, and risk considerations. A one-size-fits-all regulatory framework is unlikely to account for these differences and may unintentionally impede the beneficial adoption of technologies that can improve efficiency, strengthen controls, enhance risk management, and support better outcomes for investors.
The current regulatory framework appropriately allows advisers to tailor governance, testing, validation, monitoring, documentation, and oversight to the particular uses of AI within their organizations. This flexibility encourages responsible innovation while preserving strong investor protections and regulatory accountability.
Proportionality and Systemic Risk
As the Committee considers the regulatory framework and AI, the proportionality of risk and regulation is a key consideration. Alternative asset managers operate under a fundamentally different business model, role in the financial system, risk profile, size, complexity, and governance structure than other financial institutions, particularly global systemically important institutions. Further, each AI use case differs in materiality and risk. These differences and the proportionality of the risks and regulation for different types of financial institutions must be considered in any regulatory response.
Further, alternative asset funds do not present the risks associated with systemically important financial institutions and the use of AI should not impact this analysis. Alternative asset managers employ a diverse range of investment strategies, have asset and liability structures that match, use comparatively less leverage than other financial institutions, and are not of a similar size or complexity of other global financial institutions engaged in a wider range of activities. The use and risks of AI does not materially impact this assessment for alternative asset managers.
AI and Investment Processes
Some alternative asset managers may choose to incorporate AI into aspects of investment research, portfolio management, or trading-related processes. These applications build upon decades of experience using quantitative tools, statistical models, algorithmic processes, and other technologies in financial markets.
Importantly, existing governance, compliance, and risk management practices provide a strong foundation for overseeing these activities. Advisers employ processes for testing, validating, monitoring, and evaluating models and other technological systems used in investment decision-making and trading. In addition, trading activities remain subject to existing regulatory obligations relating to best execution, recordkeeping, compliance oversight, broker-dealer execution practices, and other established market safeguards.
Firms also employ controls designed to protect proprietary information, maintain data security, and promote operational resilience. AI models are accordingly placed in internal sandboxes and are trained on proprietary data. This prevents the proprietary information from being shared but also serves as an intrinsic check against so-called "herding" by models. Existing cybersecurity, operational risk management, incident response, and business continuity practices are likewise relevant to the use of AI and help firms manage potential risks associated with new technologies.
MFA members primarily manage assets on behalf of sophisticated institutional investors, including pension plans, endowments, foundations, insurance companies, and other large investors. Alternative asset managers providing investment advice to sophisticated institutional investors are not using AI to decide whether to offer a product or service to retail customers or the pricing of those products or services.
Conclusion
MFA believes that existing securities laws and regulations provide an effective framework for the responsible use of AI by private fund advisers. Policymakers should continue to support a technology-neutral, principles-based approach that focuses on activities, risks, and outcomes while allowing innovation and market practices to continue evolving. That said, policymakers should continue encouraging regulators to work cooperatively in examining potential risks associated with AI and in considering any potential regulatory responses. Further, policymakers should ensure that market or policy developments do not unfairly impact financial institutions of different sizes or types, for example due to early access to AI models resulting in market consequences.
We appreciate the opportunity to provide our views and would welcome further engagement with the Committee on these issues. Please do not hesitate to contact John Van Etten at jvanetten@mfaalts.org or the undersigned at jflores@mfaalts.org if you have any questions or would like to discuss further.
Sincerely,
Jillien Flores, Chief Advocacy Officer, Managed Funds Association
CC: U.S. House of Representatives Committee on Financial Services Chairman French Hill
* * *
Original text and footnotes here: https://www.mfaalts.org/wp-content/uploads/2026/08/2026-08-14-MFA-Response-with-Attachments-to-Waters-AI-RFI-vF.pdf
News Release here: https://www.mfaalts.org/press-releases/mfa-outlines-approach-to-ai-oversight-in-capital-markets/
[Category: Financial Services]
* * *
Here is the text of the letter:
August 14, 2026
The Honorable Maxine Waters
Ranking Member
Committee on Financial Services
U.S. House of Representatives
Washington, DC 20515
Re: Request for Information on AI Risks and Modernization in Financial Services
Dear Ranking Member Waters:
Managed Funds Association1 ("MFA") appreciates the opportunity to submit comments in response to the Ranking Member's ... Show Full Article WASHINGTON, Aug. 21 (TNSletter) -- The Managed Funds Association issued the following letter to Rep. Maxine Waters, D-California, ranking member of the House Financial Services Committee: * * * Here is the text of the letter: August 14, 2026 The Honorable Maxine Waters Ranking Member Committee on Financial Services U.S. House of Representatives Washington, DC 20515 Re: Request for Information on AI Risks and Modernization in Financial Services Dear Ranking Member Waters: Managed Funds Association1 ("MFA") appreciates the opportunity to submit comments in response to the Ranking Member'sRequest for Information ("RFI") regarding artificial intelligence ("AI") risks and modernization in financial services. MFA recognizes the important role policymakers play in better understanding this rapidly evolving technology, how it impacts markets and investors, and whether regulatory changes are warranted. MFA is committed to being a resource to policymakers globally as this important work moves forward.
Attached are MFA's prior submissions to the U.S. Department of the Treasury and the Financial Stability Board regarding AI. These submissions address many of the broader policy considerations raised in the RFI and underscore the importance of maintaining a proportionate, technology-neutral, and principles-based approach to AI oversight.
High-Level Considerations Regarding AI
As policymakers consider the role of AI in financial markets, several considerations should guide the discussion:
* First, existing securities laws already provide a robust framework governing the use of AI by investment advisers. Investment advisers remain responsible for complying with their legal and regulatory obligations regardless of whether they perform a function through employees, traditional software, quantitative models, algorithms, or AI-enabled tools.
* Second, AI technologies and use cases continue to evolve rapidly. Because AI is being deployed differently across firms and functions, policymakers should avoid prescriptive or technology-specific requirements that may quickly become outdated, discourage beneficial innovation, or impose unnecessary compliance burdens without corresponding investor protection benefits.
* Third, AI should be viewed mainly as a technological tool rather than a distinct regulated activity. Alternative asset managers use a wide range of technologies to support investment research, portfolio management, trading, compliance, risk management, cybersecurity, operations, and investor communications. The federal securities laws generally do not regulate particular technologies. Instead, they establish principles-based obligations governing how regulated activities are conducted and the outcomes firms must achieve.
For these reasons, policymakers should continue to evaluate AI through a technology-neutral framework focused on activities, risks, and outcomes rather than through rules directed at a specific technology.
Existing Regulatory Framework Already Governs the Use of AI
The Investment Advisers Act of 1940 and the SEC's rules thereunder already provide a comprehensive framework governing how private fund advisers develop, oversee, and deploy AI. Investment advisers are fiduciaries and must act in the best interests of their clients and investors. The SEC has recently reiterated that existing fiduciary standards apply to the use of AI, and that AI-related compliance remains an examination priority.
* Existing Fiduciary Requirements - Existing fiduciary obligations require advisers to exercise appropriate oversight and judgment when using AI, just as they do when using other technologies or third-party service providers. These principles-based standards are particularly well-suited to rapidly evolving technologies because they allow firms to tailor governance, testing, monitoring, and controls to the specific use cases and risks presented.
* Existing Regulatory Requirements - Beyond fiduciary obligations, advisers are subject to a broad range of existing regulatory requirements that are relevant to AI-enabled activities. These include requirements relating to compliance programs, books and records, disclosures, best execution, trading controls, vendor oversight, and other supervisory and governance obligations. These requirements provide regulators with significant visibility into adviser operations and create clear accountability for firm conduct.
This approach is consistent with how securities regulation has historically accommodated technological innovation. Over time, advisers have adopted increasingly sophisticated software, quantitative models, algorithmic systems, cloud computing technologies, cybersecurity tools, and operational platforms. Regulators generally have not created separate regulatory regimes for each new technology. Instead, existing principles-based obligations have applied regardless of the specific tools firms choose to use.
AI Use Cases Continue to Evolve
AI is being used across a wide range of business functions, including investment research, operational efficiency, compliance monitoring, cybersecurity, data analysis, trade support, and risk management. The scope and sophistication of these applications continue to develop rapidly.
The diversity of AI use cases underscores the importance of maintaining a flexible, principles-based regulatory approach. Different applications present different benefits, limitations, and risk considerations. A one-size-fits-all regulatory framework is unlikely to account for these differences and may unintentionally impede the beneficial adoption of technologies that can improve efficiency, strengthen controls, enhance risk management, and support better outcomes for investors.
The current regulatory framework appropriately allows advisers to tailor governance, testing, validation, monitoring, documentation, and oversight to the particular uses of AI within their organizations. This flexibility encourages responsible innovation while preserving strong investor protections and regulatory accountability.
Proportionality and Systemic Risk
As the Committee considers the regulatory framework and AI, the proportionality of risk and regulation is a key consideration. Alternative asset managers operate under a fundamentally different business model, role in the financial system, risk profile, size, complexity, and governance structure than other financial institutions, particularly global systemically important institutions. Further, each AI use case differs in materiality and risk. These differences and the proportionality of the risks and regulation for different types of financial institutions must be considered in any regulatory response.
Further, alternative asset funds do not present the risks associated with systemically important financial institutions and the use of AI should not impact this analysis. Alternative asset managers employ a diverse range of investment strategies, have asset and liability structures that match, use comparatively less leverage than other financial institutions, and are not of a similar size or complexity of other global financial institutions engaged in a wider range of activities. The use and risks of AI does not materially impact this assessment for alternative asset managers.
AI and Investment Processes
Some alternative asset managers may choose to incorporate AI into aspects of investment research, portfolio management, or trading-related processes. These applications build upon decades of experience using quantitative tools, statistical models, algorithmic processes, and other technologies in financial markets.
Importantly, existing governance, compliance, and risk management practices provide a strong foundation for overseeing these activities. Advisers employ processes for testing, validating, monitoring, and evaluating models and other technological systems used in investment decision-making and trading. In addition, trading activities remain subject to existing regulatory obligations relating to best execution, recordkeeping, compliance oversight, broker-dealer execution practices, and other established market safeguards.
Firms also employ controls designed to protect proprietary information, maintain data security, and promote operational resilience. AI models are accordingly placed in internal sandboxes and are trained on proprietary data. This prevents the proprietary information from being shared but also serves as an intrinsic check against so-called "herding" by models. Existing cybersecurity, operational risk management, incident response, and business continuity practices are likewise relevant to the use of AI and help firms manage potential risks associated with new technologies.
MFA members primarily manage assets on behalf of sophisticated institutional investors, including pension plans, endowments, foundations, insurance companies, and other large investors. Alternative asset managers providing investment advice to sophisticated institutional investors are not using AI to decide whether to offer a product or service to retail customers or the pricing of those products or services.
Conclusion
MFA believes that existing securities laws and regulations provide an effective framework for the responsible use of AI by private fund advisers. Policymakers should continue to support a technology-neutral, principles-based approach that focuses on activities, risks, and outcomes while allowing innovation and market practices to continue evolving. That said, policymakers should continue encouraging regulators to work cooperatively in examining potential risks associated with AI and in considering any potential regulatory responses. Further, policymakers should ensure that market or policy developments do not unfairly impact financial institutions of different sizes or types, for example due to early access to AI models resulting in market consequences.
We appreciate the opportunity to provide our views and would welcome further engagement with the Committee on these issues. Please do not hesitate to contact John Van Etten at jvanetten@mfaalts.org or the undersigned at jflores@mfaalts.org if you have any questions or would like to discuss further.
Sincerely,
Jillien Flores, Chief Advocacy Officer, Managed Funds Association
CC: U.S. House of Representatives Committee on Financial Services Chairman French Hill
* * *
Original text and footnotes here: https://www.mfaalts.org/wp-content/uploads/2026/08/2026-08-14-MFA-Response-with-Attachments-to-Waters-AI-RFI-vF.pdf
News Release here: https://www.mfaalts.org/press-releases/mfa-outlines-approach-to-ai-oversight-in-capital-markets/
[Category: Financial Services]
Dr. Mohamad Alkhouli Named Editor-in-Chief of JACC: Cardiovascular Interventions
WASHINGTON, Aug. 21 -- The American College of Cardiology posted the following news release on Aug. 20, 2026:
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Dr. Mohamad Alkhouli Named Editor-in-Chief of JACC: Cardiovascular Interventions
Alkhouli to lead journal through a rapidly evolving era of cardiovascular care
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The American College of Cardiology announced today the appointment of Mohamad Alkhouli, MD, MBA, as the new editor-in-chief of JACC: Cardiovascular Interventions. Alkhouli brings to the journal an internationally recognized career in interventional cardiology and cardiovascular research, along with more than a decade ... Show Full Article WASHINGTON, Aug. 21 -- The American College of Cardiology posted the following news release on Aug. 20, 2026: * * * Dr. Mohamad Alkhouli Named Editor-in-Chief of JACC: Cardiovascular Interventions Alkhouli to lead journal through a rapidly evolving era of cardiovascular care - The American College of Cardiology announced today the appointment of Mohamad Alkhouli, MD, MBA, as the new editor-in-chief of JACC: Cardiovascular Interventions. Alkhouli brings to the journal an internationally recognized career in interventional cardiology and cardiovascular research, along with more than a decadeof editorial leadership experience at leading cardiovascular journals.
As Editor-in-Chief of JACC: Cardiovascular Interventions, Alkhouli said he aims to build on the journal's strong foundation and further its role as a defining voice in the future of interventional cardiovascular medicine.
"It is a profound honor to lead the next chapter of JACC: Cardiovascular Interventions, a journal that has helped shape interventional cardiology for nearly two decades," Alkhouli said. "As our field enters an extraordinary era of discovery and transformation, the journal must not only evolve with it but help illuminate the path forward. My aspiration is to lead with rigor, curiosity and openness and to ensure that the best ideas, wherever they arise, are recognized, elevated and ultimately translated into better care for the patients we serve."
Alkhouli is a professor of medicine at Mayo Clinic School of Medicine in Rochester, Minnesota, where he maintains an active clinical practice in complex coronary and structural heart interventions. He earned his medical degree from Damascus University and completed residency and cardiovascular fellowship training at Temple University, followed by advanced training in coronary and structural heart interventions at the University of Rochester and Mayo Clinic.
An internationally recognized cardiovascular investigator, Alkhouli has authored or co-authored more than 550 peer-reviewed publications, including pivotal clinical studies and influential research published in Circulation, JAMA, JACC, European Heart Journal, and the New England Journal of Medicine. His work spans coronary and structural heart disease, intracardiac imaging, stroke prevention, heart-brain interactions, cardiovascular hemodynamics, and artificial intelligence. He is a frequent speaker at major international cardiology meetings and has been invited to lecture as a visiting professor and keynote speaker in more than 20 countries.
Beyond his clinical and scientific work, Alkhouli brings expertise in management, innovation, and complex systems. He holds an Executive MBA from MIT and has pursued advanced executive education in innovation, entrepreneurship, and system dynamics at MIT and Stanford University. At Mayo Clinic, he serves as Vice Chair for Strategic Partnerships and Medical Director of the Cardiovascular Innovation Summit. Within the American College of Cardiology, he has served on the Minnesota ACC Board of Governors and the steering committees of the TVT and LAAO registries, and most recently as Deputy Editor of JACC: Cardiovascular Interventions.
"Dr. Alkhouli has the brilliance, competence, and temperament to be an extraordinary editor and to bring an already strong journal to the next level," said Harlan M. Krumholz, MD, SM, MACC, FAHA, Editor-in-Chief of JACC and the Harold H. Hines, Jr Professor at the Yale School of Medicine. "This is exactly the moment the field needs trusted sources of information and for journals to use their influence to strengthen communities and lead the effort to advance global cardiovascular health."
JACC: Cardiovascular Interventions publishes peer-reviewed articles encompassing the entire field of interventional cardiovascular medicine, including case selection and management, procedural techniques, complications of coronary intervention, catheter-based management of noncoronary arterial disease, cardiovascular imaging, physiologic assessment and other advances that inform clinical practice and improve patient care. For more information, visit About | JACC: Cardiovascular Interventions.
* * *
The American College of Cardiology (ACC) is a global leader dedicated to transforming cardiovascular care and improving heart health for all. For more than 75 years, the ACC has empowered a community of over 60,000 cardiovascular professionals across more than 140 countries with cutting-edge education and advocacy, rigorous professional credentials, and trusted clinical guidance. From its world-class JACC Journals and NCDR registries to its Accreditation Services, global network of Chapters and Sections, and CardioSmart patient initiatives, the College is committed to creating a world where science, knowledge and innovation optimize patient care and outcomes. Learn more at www.ACC.org or connect on social media at @ACCinTouch.
* * *
The ACC's JACC Journals rank among the top cardiovascular journals in the world for scientific impact. The flagship journal, the Journal of the American College of Cardiology (JACC) -- and specialty journals consisting of JACC: Advances, JACC: Asia, JACC: Basic to Translational Science, JACC: CardioOncology, JACC: Cardiovascular Imaging, JACC: Cardiovascular Interventions, JACC: Case Reports, JACC: Clinical Electrophysiology and JACC: Heart Failure -- pride themselves on publishing the top peer-reviewed research on all aspects of cardiovascular disease. Learn more at JACC.org.
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Original text here: https://www.acc.org/About-ACC/Press-Releases/2026/08/20/16/58/Dr-Mohamad-Alkhouli-Named-Editor-in-Chief-of-JACC-Cardiovascular-Interventions
[Category: Medical]
* * *
Dr. Mohamad Alkhouli Named Editor-in-Chief of JACC: Cardiovascular Interventions
Alkhouli to lead journal through a rapidly evolving era of cardiovascular care
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The American College of Cardiology announced today the appointment of Mohamad Alkhouli, MD, MBA, as the new editor-in-chief of JACC: Cardiovascular Interventions. Alkhouli brings to the journal an internationally recognized career in interventional cardiology and cardiovascular research, along with more than a decade ... Show Full Article WASHINGTON, Aug. 21 -- The American College of Cardiology posted the following news release on Aug. 20, 2026: * * * Dr. Mohamad Alkhouli Named Editor-in-Chief of JACC: Cardiovascular Interventions Alkhouli to lead journal through a rapidly evolving era of cardiovascular care - The American College of Cardiology announced today the appointment of Mohamad Alkhouli, MD, MBA, as the new editor-in-chief of JACC: Cardiovascular Interventions. Alkhouli brings to the journal an internationally recognized career in interventional cardiology and cardiovascular research, along with more than a decadeof editorial leadership experience at leading cardiovascular journals.
As Editor-in-Chief of JACC: Cardiovascular Interventions, Alkhouli said he aims to build on the journal's strong foundation and further its role as a defining voice in the future of interventional cardiovascular medicine.
"It is a profound honor to lead the next chapter of JACC: Cardiovascular Interventions, a journal that has helped shape interventional cardiology for nearly two decades," Alkhouli said. "As our field enters an extraordinary era of discovery and transformation, the journal must not only evolve with it but help illuminate the path forward. My aspiration is to lead with rigor, curiosity and openness and to ensure that the best ideas, wherever they arise, are recognized, elevated and ultimately translated into better care for the patients we serve."
Alkhouli is a professor of medicine at Mayo Clinic School of Medicine in Rochester, Minnesota, where he maintains an active clinical practice in complex coronary and structural heart interventions. He earned his medical degree from Damascus University and completed residency and cardiovascular fellowship training at Temple University, followed by advanced training in coronary and structural heart interventions at the University of Rochester and Mayo Clinic.
An internationally recognized cardiovascular investigator, Alkhouli has authored or co-authored more than 550 peer-reviewed publications, including pivotal clinical studies and influential research published in Circulation, JAMA, JACC, European Heart Journal, and the New England Journal of Medicine. His work spans coronary and structural heart disease, intracardiac imaging, stroke prevention, heart-brain interactions, cardiovascular hemodynamics, and artificial intelligence. He is a frequent speaker at major international cardiology meetings and has been invited to lecture as a visiting professor and keynote speaker in more than 20 countries.
Beyond his clinical and scientific work, Alkhouli brings expertise in management, innovation, and complex systems. He holds an Executive MBA from MIT and has pursued advanced executive education in innovation, entrepreneurship, and system dynamics at MIT and Stanford University. At Mayo Clinic, he serves as Vice Chair for Strategic Partnerships and Medical Director of the Cardiovascular Innovation Summit. Within the American College of Cardiology, he has served on the Minnesota ACC Board of Governors and the steering committees of the TVT and LAAO registries, and most recently as Deputy Editor of JACC: Cardiovascular Interventions.
"Dr. Alkhouli has the brilliance, competence, and temperament to be an extraordinary editor and to bring an already strong journal to the next level," said Harlan M. Krumholz, MD, SM, MACC, FAHA, Editor-in-Chief of JACC and the Harold H. Hines, Jr Professor at the Yale School of Medicine. "This is exactly the moment the field needs trusted sources of information and for journals to use their influence to strengthen communities and lead the effort to advance global cardiovascular health."
JACC: Cardiovascular Interventions publishes peer-reviewed articles encompassing the entire field of interventional cardiovascular medicine, including case selection and management, procedural techniques, complications of coronary intervention, catheter-based management of noncoronary arterial disease, cardiovascular imaging, physiologic assessment and other advances that inform clinical practice and improve patient care. For more information, visit About | JACC: Cardiovascular Interventions.
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The American College of Cardiology (ACC) is a global leader dedicated to transforming cardiovascular care and improving heart health for all. For more than 75 years, the ACC has empowered a community of over 60,000 cardiovascular professionals across more than 140 countries with cutting-edge education and advocacy, rigorous professional credentials, and trusted clinical guidance. From its world-class JACC Journals and NCDR registries to its Accreditation Services, global network of Chapters and Sections, and CardioSmart patient initiatives, the College is committed to creating a world where science, knowledge and innovation optimize patient care and outcomes. Learn more at www.ACC.org or connect on social media at @ACCinTouch.
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The ACC's JACC Journals rank among the top cardiovascular journals in the world for scientific impact. The flagship journal, the Journal of the American College of Cardiology (JACC) -- and specialty journals consisting of JACC: Advances, JACC: Asia, JACC: Basic to Translational Science, JACC: CardioOncology, JACC: Cardiovascular Imaging, JACC: Cardiovascular Interventions, JACC: Case Reports, JACC: Clinical Electrophysiology and JACC: Heart Failure -- pride themselves on publishing the top peer-reviewed research on all aspects of cardiovascular disease. Learn more at JACC.org.
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Original text here: https://www.acc.org/About-ACC/Press-Releases/2026/08/20/16/58/Dr-Mohamad-Alkhouli-Named-Editor-in-Chief-of-JACC-Cardiovascular-Interventions
[Category: Medical]
Atlantic States Marine Fisheries Striped Bass Assessment Workshop, Cobia Methods Workshop, and Spot Stock Assessment Committee Planning Meetings
ARLINGTON, Virginia, Aug. 21 -- The Atlantic States Marine Fisheries Commission issued the following news release on Aug. 20, 2026:
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ASMFC Stock Assessment Happenings
Upcoming Meetings: Atlantic Striped Bass Assessment Workshop, Cobia Methods Workshop, and Spot Stock Assessment Committee Planning Meetings
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The Atlantic States Marine Fisheries Commission's stock assessment staff, working in conjunction with state and federal stock assessment scientists, continue to make progress on a number benchmark stock assessments.
Additionally, in the coming month, the Commission will post a speciesspecific ... Show Full Article ARLINGTON, Virginia, Aug. 21 -- The Atlantic States Marine Fisheries Commission issued the following news release on Aug. 20, 2026: * * * ASMFC Stock Assessment Happenings Upcoming Meetings: Atlantic Striped Bass Assessment Workshop, Cobia Methods Workshop, and Spot Stock Assessment Committee Planning Meetings - The Atlantic States Marine Fisheries Commission's stock assessment staff, working in conjunction with state and federal stock assessment scientists, continue to make progress on a number benchmark stock assessments. Additionally, in the coming month, the Commission will post a speciesspecificBenchmark Stock Assessment Tracker webpage, much like our Action Trackers, to increase transparency in our stock assessment process by enabling stakeholders to track benchmark assessment development and where we are in the assessment process. A press release will announce their availability. In the interim, here's a snapshot of recent and upcoming assessment activities.
Atlantic Croaker
The Atlantic Croaker Benchmark Stock Assessment Peer Review was conducted July 27-30, 2026, in Arlington, VA. The results of both the benchmark stock assessment and peer review will be presented to the Sciaenids Management Board for consideration in November 2026 at the Commission's Annual Meeting in Newport, Rhode Island.
Atlantic Migratory Group Cobia
In March and April of this year, the Commission conducted a series of Data Workshops for the upcoming Cobia Benchmark Stock Assessment. At the first three workshops, the Technical Committee, Stock Assessment Subcommittee, and federal data partners focused on data sources for commercial and recreational fishery removals, biosampling, and life history; and available fishery-independent survey data and initial literature review findings. The final workshop included a discussion about indices of abundance, tagging data, preparation for the next workshop on assessment methods, and other items as needed from the previous workshops.
A Methods Workshop, to be held September 22-25, 2026, in Raleigh, NC, will include an evaluation of models and analyses developed to estimate stock status, with the Stock Assessment Subcommittee making final selections regarding data and model structure. The Assessment Workshop is scheduled for December 2026, with the peer review being conducted through the SouthEast Data, Assessment, and Review (SEDAR) process in May 2027.
Atlantic Striped Bass
A Data Workshop was held in October 2025, followed by a Methods Workshop in March 2026. The Atlantic Striped Bass Stock Assessment Workshop will be held August 24-28, 2026, at the Commission office at 1050 N. Highland Street, Suite 200 A-N, Arlington, VA. This workshop, which is accessible online and in-person, will focus on evaluation of models and analyses developed to determine stock status. The Commission's stock assessment meetings are open to the public, with the exception of discussions of confidential data, when the public will be asked to leave the room. Public comment will be allowed if time permits at the discretion of the Stock Assessment Subcommittee Chair. More information on the Workshop can be found here (https://asmfc.org/events/atlantic-striped-bass-assessment-workshop/).
The peer review will be conducted through Northeast Regional Stock Assessment process in May or June 2027, with the Atlantic Striped Bass Management Board scheduled to consider the benchmark assessment and peer review in August 2027 at the Commission's Summer Meeting.
Atlantic Sturgeon
In July and August of this year, the Commission conducted a series of Data Workshops for the upcoming Atlantic Sturgeon Benchmark Stock Assessment. At these workshops, the Technical Committee and the Stock Assessment Subcommittee reviewed and evaluated available data sources for the assessment, including indices of abundance, life history information, bycatch estimation, and tagging data.
The Methods Workshop will be conducted in early 2027, and the Assessment Workshop will be held in early fall 2027. The assessment will be peer-reviewed through the Commission's external peer review process in 2028.
Spot
The Commission first initiated a benchmark stock assessment for spot back in 2023. An initial Data Workshop was held in 2023, but the assessment process was put on hold so that the Atlantic Croaker Technical Committee and Stock Assessment Subcommittee, which consists of many of the same members as the Spot Committees, could focus on the Atlantic croaker benchmark assessment and peer review. With the completion of the Atlantic croaker peer review in July, the Spot Stock Assessment Committee has reinitiated the spot assessment and will conduct its first two meetings on August 31 and September 3. The focus of these meetings will be to review available data sources, as well as discuss potential models for development. Next steps, including additional workshops, will be scheduled following these two meetings; information on future meetings will be posted to the Meetings page of the Commission's website.
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Original text here: https://asmfc.org/wp-content/uploads/2026/08/pr15StockAssessmentHappenings.pdf
[Category: Environment]
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ASMFC Stock Assessment Happenings
Upcoming Meetings: Atlantic Striped Bass Assessment Workshop, Cobia Methods Workshop, and Spot Stock Assessment Committee Planning Meetings
-
The Atlantic States Marine Fisheries Commission's stock assessment staff, working in conjunction with state and federal stock assessment scientists, continue to make progress on a number benchmark stock assessments.
Additionally, in the coming month, the Commission will post a speciesspecific ... Show Full Article ARLINGTON, Virginia, Aug. 21 -- The Atlantic States Marine Fisheries Commission issued the following news release on Aug. 20, 2026: * * * ASMFC Stock Assessment Happenings Upcoming Meetings: Atlantic Striped Bass Assessment Workshop, Cobia Methods Workshop, and Spot Stock Assessment Committee Planning Meetings - The Atlantic States Marine Fisheries Commission's stock assessment staff, working in conjunction with state and federal stock assessment scientists, continue to make progress on a number benchmark stock assessments. Additionally, in the coming month, the Commission will post a speciesspecificBenchmark Stock Assessment Tracker webpage, much like our Action Trackers, to increase transparency in our stock assessment process by enabling stakeholders to track benchmark assessment development and where we are in the assessment process. A press release will announce their availability. In the interim, here's a snapshot of recent and upcoming assessment activities.
Atlantic Croaker
The Atlantic Croaker Benchmark Stock Assessment Peer Review was conducted July 27-30, 2026, in Arlington, VA. The results of both the benchmark stock assessment and peer review will be presented to the Sciaenids Management Board for consideration in November 2026 at the Commission's Annual Meeting in Newport, Rhode Island.
Atlantic Migratory Group Cobia
In March and April of this year, the Commission conducted a series of Data Workshops for the upcoming Cobia Benchmark Stock Assessment. At the first three workshops, the Technical Committee, Stock Assessment Subcommittee, and federal data partners focused on data sources for commercial and recreational fishery removals, biosampling, and life history; and available fishery-independent survey data and initial literature review findings. The final workshop included a discussion about indices of abundance, tagging data, preparation for the next workshop on assessment methods, and other items as needed from the previous workshops.
A Methods Workshop, to be held September 22-25, 2026, in Raleigh, NC, will include an evaluation of models and analyses developed to estimate stock status, with the Stock Assessment Subcommittee making final selections regarding data and model structure. The Assessment Workshop is scheduled for December 2026, with the peer review being conducted through the SouthEast Data, Assessment, and Review (SEDAR) process in May 2027.
Atlantic Striped Bass
A Data Workshop was held in October 2025, followed by a Methods Workshop in March 2026. The Atlantic Striped Bass Stock Assessment Workshop will be held August 24-28, 2026, at the Commission office at 1050 N. Highland Street, Suite 200 A-N, Arlington, VA. This workshop, which is accessible online and in-person, will focus on evaluation of models and analyses developed to determine stock status. The Commission's stock assessment meetings are open to the public, with the exception of discussions of confidential data, when the public will be asked to leave the room. Public comment will be allowed if time permits at the discretion of the Stock Assessment Subcommittee Chair. More information on the Workshop can be found here (https://asmfc.org/events/atlantic-striped-bass-assessment-workshop/).
The peer review will be conducted through Northeast Regional Stock Assessment process in May or June 2027, with the Atlantic Striped Bass Management Board scheduled to consider the benchmark assessment and peer review in August 2027 at the Commission's Summer Meeting.
Atlantic Sturgeon
In July and August of this year, the Commission conducted a series of Data Workshops for the upcoming Atlantic Sturgeon Benchmark Stock Assessment. At these workshops, the Technical Committee and the Stock Assessment Subcommittee reviewed and evaluated available data sources for the assessment, including indices of abundance, life history information, bycatch estimation, and tagging data.
The Methods Workshop will be conducted in early 2027, and the Assessment Workshop will be held in early fall 2027. The assessment will be peer-reviewed through the Commission's external peer review process in 2028.
Spot
The Commission first initiated a benchmark stock assessment for spot back in 2023. An initial Data Workshop was held in 2023, but the assessment process was put on hold so that the Atlantic Croaker Technical Committee and Stock Assessment Subcommittee, which consists of many of the same members as the Spot Committees, could focus on the Atlantic croaker benchmark assessment and peer review. With the completion of the Atlantic croaker peer review in July, the Spot Stock Assessment Committee has reinitiated the spot assessment and will conduct its first two meetings on August 31 and September 3. The focus of these meetings will be to review available data sources, as well as discuss potential models for development. Next steps, including additional workshops, will be scheduled following these two meetings; information on future meetings will be posted to the Meetings page of the Commission's website.
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Original text here: https://asmfc.org/wp-content/uploads/2026/08/pr15StockAssessmentHappenings.pdf
[Category: Environment]
American Society for Nutrition Issues Commentary: Presidential Farewell - Reflections and Gratitude From Naima Moustaid-Moussa
BETHESDA, Maryland, Aug. 21 -- The American Society for Nutrition issued the following commentary on Aug. 20, 2026, by President Naima Moustaid-Moussa:
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A Presidential Farewell: Reflections and Gratitude from Naima Moustaid-Moussa
It has been an honor to serve as the 2025-2026 President of the American Society for Nutrition (ASN). Over the past year, I have had the privilege of working alongside an extraordinary community of scientists, clinicians, educators, students, and staff dedicated to advancing nutrition science. ASN is a vibrant and diverse scientific society spanning basic and ... Show Full Article BETHESDA, Maryland, Aug. 21 -- The American Society for Nutrition issued the following commentary on Aug. 20, 2026, by President Naima Moustaid-Moussa: * * * A Presidential Farewell: Reflections and Gratitude from Naima Moustaid-Moussa It has been an honor to serve as the 2025-2026 President of the American Society for Nutrition (ASN). Over the past year, I have had the privilege of working alongside an extraordinary community of scientists, clinicians, educators, students, and staff dedicated to advancing nutrition science. ASN is a vibrant and diverse scientific society spanning basic andclinical research, translational and community-based research, policy, and practice. Our Society is strong because of the commitment of our members, leaders, and staff who work together to uphold scientific rigor and advance nutrition.
It has been a privilege to work alongside many of you during a time when nutrition has become a national and global focal point, bringing both significant progress and challenges for our field. My presidency concluded with NUTRITION 2026, where our community came together to celebrate scientific progress, strengthen collaborations, and look ahead to the future.
It was an immense pleasure to welcome the nearly 3,000 scientists, clinicians, educators, students, early career scientists, and other professionals from 57 countries, including the United States and U.S. minor outlying islands to share discoveries, exchange ideas, challenge existing ideas, build collaborations, mentor emerging scientists, and help shape the future of nutrition science.
My sincere thanks to everyone who attended NUTRITION 2026. The amazing science presented throughout the meeting reflected the hard work, dedication, and innovation of our members and attendees. For those who were unable to join us, I encourage you to take time to view the recorded main lectures and award sessions when they become available in the coming months.
NUTRITION 2026 began with a pre-conference workshop on AI and Precision Nutrition, highlighting NIH's Nutrition for Precision Health initiative powered by the All of Us Research Program. Scientific sessions throughout the meeting addressed a broad range of topics, including ultra-processed foods, Food is Medicine, infant nutrition, and sustainable food systems. Equally important were the conversations that fostered new ideas, strengthened collaborations, and created opportunities to learn from and mentor the next generation of nutrition scientists.
As I shared during the Opening Session, nutrition science made significant advances in discovery and innovation over the past year while also facing significant challenges. Many members of our community navigated uncertainty surrounding research funding, training opportunities, and scientific careers, along with growing concerns about scientific rigor and integrity, misinformation, and transparency. Protecting the foundations of science, including rigorous peer review, collaboration, open exchange of ideas, and sustained investment in research and workforce development remains essential to future discovery. ASN has consistently championed evidence-based nutrition and will continue to advocate for rigorous, transparent, and trusted science.
During NUTRITION 2026, we also celebrated the people who make our Society exceptional. We remembered members of our community who passed away during the past year, whose scientific achievements, mentorship, and dedication have helped shape our field and will continue to influence future generations. We recognized the second cohort of 69 Excellence in Nutrition Fellows for their outstanding professional achievements and significant contributions to nutrition science, education, and practice. Together with ASN Foundation Chair Paul Coates, I also had the privilege of recognizing the 21 members of the Class of 2026 Distinguished Fellows, who were formally inducted during the Fellows Lunch. Distinguished Fellow is ASN's highest honor, recognizing members with more than 30 years of dedicated service to the Society whose careers have demonstrated sustained excellence and made enduring contributions to nutrition science. We also celebrated our members with more than 50 years of membership and our past presidents, whose leadership, scholarship, and commitment have helped strengthen our Society, our community, and nutrition science.
Despite the challenges we face, I remain optimistic about the future of our field. Through our continued innovation, creativity, persistence, and dedication to evidence-based nutrition science, we will continue advancing knowledge and discovery, mentoring emerging scientists, improving patient care, and moving nutrition science forward to impact public health.
That commitment to excellence is also reflected in ASN's four journals, all of which achieved increases in their Impact Factors this year: Advances in Nutrition, The Journal of Nutrition, Current Developments in Nutrition, and The American Journal of Clinical Nutrition. These achievements are more than performance metrics. They reflect the strength of peer review and the trust placed in scientific rigor, which are essential to improving human nutrition and health and informing policy. Continued progress is only achieved through trust and collaboration. Our field is too complex and multidisciplinary for any one researcher, institution, discipline, or sector to address alone.
Partnerships and collaborations remain central to ASN's mission, and NUTRITION 2026 demonstrated the value of bringing people together to share ideas, learn from one another, build connections, and support the next generation of nutrition scientists and educators. I am so grateful to the Scientific Program Committee, led by Cristina Palacios, PhD, FASN, and Raz Shaikh, PhD, FASN, and to all of the committee members for developing a first-class scientific program that featured more than 2,000 scientific presentations spanning basic, clinical, translational, and population science over four days.
A great way to start the meeting was the Opening Session, "Dietary Guidance at a Crossroads: Science, Practice, and Innovation," chaired by Johanna Dwyer, DSc, RD, DFASN, a pioneer and one of the most respected voices in our field, as well as a Distinguished Fellow, past ASN President, and member of the National Academy of Medicine. The session explored the science that informs dietary guidance, the processes and challenges of translating recommendations into practice, and opportunities to strengthen dietary guidance moving forward. Speakers included members of previous Dietary Guidelines Advisory Committees, Sarah Booth, PhD, Hollie Raynor, PhD, RD, LDN, DFASN, and Bruce Y. Lee, MD, MBA, who engaged with questions and perspectives from the audience as well as questions submitted in advance of the meeting. The discussion reflected the shared commitment of the panel and audience to advance dietary guidance and emphasized the importance of transparent and constructive dialogue in strengthening both the science and the process of developing dietary guidance.
Other highlights included my Presidential Symposium, "Connect with the Fed" sessions, award lectures, flash talks and poster sessions, professional development activities, networking events for students and early career professionals, and daily ASN event summaries featuring video messages from leaders in academia, government, and organizations across the United States and around the world. The spirit of scientific rigor, interdisciplinary collaboration, workforce development, and mentorship was evident throughout the program.
For the first time at an ASN NUTRITION meeting, the Presidential Symposium focused on "One Health in a Global Context: At the Crossroads of Food Systems, Nutrition, and Human Health." The session gathered global leaders in One Health, food systems, and community impact. Keynote speakers Ismahane Elouafi, PhD, Executive Managing Director of the Consultative Group on International Agricultural Research (CGIAR), and Tahmeed Hamed, PhD, Executive Director of the International Centre for Diarrhoeal Disease Research, Bangladesh (icddr,b), both recognized among TIME's 100 Most Influential People of 2025, shared perspectives on how climate-resilient agriculture, diversified food systems, and locally driven solutions can improve diets and health outcomes, particularly for women and children living in climate-stressed and food-insecure settings.
The NUTRITION 2026 program was comprehensive and transdisciplinary, showcasing rigorous and energizing science across a broad range of topics. The breadth and complexity of the science presented reminded us that meaningful progress requires collaboration, creativity, and a willingness to learn from one another while mentoring the next generation of nutrition scientists. Some of the most meaningful connections happen beyond the formal sessions - through poster presentations, hallway discussions, and informal exchanges. I am so grateful for ASN's annual meetings because they have opened doors to collaborations that have shaped and catalyzed my own scientific journey. These connections and learning experiences are what make the NUTRITION meetings so special. It is the gathering of the nutrition community to build collaborations, share knowledge, and mentor one another that is ultimately what advances nutrition science and improves health.
2025-2026 Presidential Report
Presidential Vision
My presidential vision was to expand and strengthen ASN's reach and impact through global partnerships and a One Health approach that connects nutrition with food systems, agriculture, and health.
My priorities were to:
1. Expand ASN's leadership role in advocacy, policy, and education in the United States and globally to support its members.
2. Broaden the scope of nutrition through the transdisciplinary lens of One Health.
3. Advance ASN's global connections and partnerships.
4. Organize regional conferences and workshops on specific topics related to basic and translational nutrition.
Goal 1. Expand ASN's leadership role in advocacy, policy, and education
ASN membership reached a record-breaking number of over 9,000 members. This growth was supported in part through partnerships with the Academic Nutrition Departments and Programs (ANDP) and American Society for Nutrition Foundation (ASNF) Presidential Student Scholarships, as well as global partnerships.
At the policy level, ASN proactively responded to various proposed federal policies, shared ASN's expertise with federal agencies, including the National Institutes of Health (NIH) and the U.S. Department of Agriculture (USDA), and led the Friends of ONR coalition in advocating for a historic increase in funding for the NIH Office of Nutrition Research (ONR) in Fiscal Year 2026.
Goal 2. Broaden the scope of nutrition through the transdisciplinary lens of One Health
I worked to advance One Health as a framework for connecting nutrition with food systems, agriculture, environmental health, and human health.
Key activities included:
* Co-editing a special issue on "Advancing One Health" for The Journal of Nutrition with Ismahane Elouafi, PhD, and Ron L. Cook, DO, MBA.
* Presenting on One Health, Food Systems, and Nutrition at international and regional meetings including the International Union of Nutritional Sciences (IUNS)-International Congress of Nutrition (ICN) in Paris; the Moroccan Society for Nutrition, Health and Environment meeting; and the Asian American Nutrition & Health Summit 2026, organized by the Asian Americans and Pacific Islanders Member Interest Group within the Academy of Nutrition and Dietetics.
* Highlighting Global One Health, Food Systems, and Nutrition during the NUTRITION 2026 Presidential Symposium, with additional abstracts addressing One Health.
* Exploring opportunities for ASN to partner with the North America One Health University Network through my role on its steering committee.
Goal 3. Advance ASN's global connections and partnerships
A major focus of my presidency was strengthening ASN's global presence and developing partnerships that support nutrition science, evidence-based nutrition, knowledge exchange, capacity building, and opportunities for early career professionals and student members. Progress included:
* Established a partnership with the Moroccan Society for Nutrition, Health and Environment (SMNSE) with a Memorandum of Understanding (MOU) signed in December 2025.
* Advanced an MOU with the Emirates Nutrition Association (ENA) to discuss co-sponsorship of leadership workshops and scientific conferences.
* Formalized a strategic alliance with The Obesity Society (TOS) in June 2026.
* Initiated discussions about additional partnerships with the Society for Nutrition Education and Behavior (SNEB), the American Society for Parenteral and Enteral Nutrition (ASPEN), and the International Society for the Study of Fatty Acids and Lipids (ISSFAL).
* Developed a strategic alliance with the National Academies of Sciences, Engineering, and Medicine (NASEM) Food, Nutrition, and Agriculture (FNA) Program Area, which held special sessions during NUTRITION 2026 to update ASN members and attendees on recent restructuring and priorities.
* Expanded engagement with global organizations through meetings, conferences, and discussions about potential partnerships, including the International Atomic Energy Agency (IAEA), CGIAR, the Food and Agriculture Organization (FAO) of the United Nations, the World Health Organization (WHO), the Federation of African Nutrition Societies (FANUS), Nutrition Society of South Africa (NSSA), and North American Chinese Association for Nutrition (NACAN).
These partnership activities expanded ASN's visibility and created opportunities to advance nutrition science, evidence-based nutrition, mentoring, education, and professional development.
Goal 4. Organize regional conferences and workshops
A key goal was to re-engage more basic and translational scientists in ASN and expand membership and collaboration through topical conferences and workshops.
ASN engaged with the ANDP community for co-sponsored regional conferences, including co-sponsoring the 22nd Annual Russell Klein Nutrition Research Symposium, held at The Ohio State University on March 31, 2026.
Additional discussions are underway with partner organizations, including SMNSE, ENA, and TOS, to develop regional and global conferences and scientific sessions or workshops focused on topics of shared interest.
Other Important ASN-supported Initiatives
In addition to these presidential priorities, several other important initiatives advanced during the year. These included the LANTERN (Laboratory Animal Nutrition Taskforce for an Education and Research Network) proposed action plan focused on rigor in the design of animal diets, continued partnership and collaboration with ASNF planning for the ASN Centennial in 2028, and record-breaking engagement among Sustaining Partners.
We also celebrated important advances in clinical nutrition including:
* Establishment of a new Physician Nutrition GEM (Group Engaging Members).
* The WHO New ICD (International Classification of Diseases version 11) Code for Undernutrition in Clinical Settings for Adults.
* Continued collaboration with the National Board of Physician Nutrition Specialists (NBPNS), who ASN partnered with to gain approval of a new Centers for Medicare & Medicaid Services (CMS) physician specialty code which will allow Physician Nutrition Specialists to get reimbursement for their services starting on October 1, a huge professional and policy win for Physician Nutrition Specialists.
Together, these accomplishments strengthen the role of ASN and its affiliated organizations in advancing clinical nutrition and create new opportunities to engage physicians in nutrition science and ASN.
Listening to Our Members
ASN's 2026 member survey provided valuable insight into the needs and priorities of our community. Members identified nutrition meetings, ASN journals, networking, and opportunities to contribute to the field among the most valued aspects of membership.
Members also identified challenges, including research funding, publishing costs, misinformation, policy and regulatory barriers. Early career members highlighted additional needs, including finding mentors, building professional networks, identifying collaborators, and job hunting.
Overall, satisfaction with the ASN membership experience remained high, although needs and perceived benefits varied across different career stages. Based on this feedback, ASN staff are developing strategies to strengthen engagement with current members, recruit new members, and address concerns and priorities identified through the survey.
A Final Note
I am grateful for the opportunity to serve as ASN President and for the dedication of our members, volunteer leaders, and staff throughout the past year. Together, we have strengthened ASN's reach and impact, built new global partnerships, advanced One Health, and supported our growing community. I am confident that ASN will build on this progress to advance nutrition science and improve health in the years ahead.
I would like to add special thanks to John Courtney, Ph.D., ASN's Chief Executive Officer for his leadership and support and his collaborative work with ASN leaders, staff, partners and members. No presidential vision would be achieved without John and our highly dedicated staff who in fact are the ones realizing presidential visions time after time and serve the nutrition community to advance science and impact public health.
I am very grateful to thank my family for their unconditional support, and especially my husband for being a great entertainer and first man! Many thanks to Sophia Pena, for her amazing support throughout my presidency and in my regular job!
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Original text here: https://nutrition.org/a-presidential-farewell-reflections-and-gratitude-from-naima-moustaid-moussa/
[Category: Health Care]
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A Presidential Farewell: Reflections and Gratitude from Naima Moustaid-Moussa
It has been an honor to serve as the 2025-2026 President of the American Society for Nutrition (ASN). Over the past year, I have had the privilege of working alongside an extraordinary community of scientists, clinicians, educators, students, and staff dedicated to advancing nutrition science. ASN is a vibrant and diverse scientific society spanning basic and ... Show Full Article BETHESDA, Maryland, Aug. 21 -- The American Society for Nutrition issued the following commentary on Aug. 20, 2026, by President Naima Moustaid-Moussa: * * * A Presidential Farewell: Reflections and Gratitude from Naima Moustaid-Moussa It has been an honor to serve as the 2025-2026 President of the American Society for Nutrition (ASN). Over the past year, I have had the privilege of working alongside an extraordinary community of scientists, clinicians, educators, students, and staff dedicated to advancing nutrition science. ASN is a vibrant and diverse scientific society spanning basic andclinical research, translational and community-based research, policy, and practice. Our Society is strong because of the commitment of our members, leaders, and staff who work together to uphold scientific rigor and advance nutrition.
It has been a privilege to work alongside many of you during a time when nutrition has become a national and global focal point, bringing both significant progress and challenges for our field. My presidency concluded with NUTRITION 2026, where our community came together to celebrate scientific progress, strengthen collaborations, and look ahead to the future.
It was an immense pleasure to welcome the nearly 3,000 scientists, clinicians, educators, students, early career scientists, and other professionals from 57 countries, including the United States and U.S. minor outlying islands to share discoveries, exchange ideas, challenge existing ideas, build collaborations, mentor emerging scientists, and help shape the future of nutrition science.
My sincere thanks to everyone who attended NUTRITION 2026. The amazing science presented throughout the meeting reflected the hard work, dedication, and innovation of our members and attendees. For those who were unable to join us, I encourage you to take time to view the recorded main lectures and award sessions when they become available in the coming months.
NUTRITION 2026 began with a pre-conference workshop on AI and Precision Nutrition, highlighting NIH's Nutrition for Precision Health initiative powered by the All of Us Research Program. Scientific sessions throughout the meeting addressed a broad range of topics, including ultra-processed foods, Food is Medicine, infant nutrition, and sustainable food systems. Equally important were the conversations that fostered new ideas, strengthened collaborations, and created opportunities to learn from and mentor the next generation of nutrition scientists.
As I shared during the Opening Session, nutrition science made significant advances in discovery and innovation over the past year while also facing significant challenges. Many members of our community navigated uncertainty surrounding research funding, training opportunities, and scientific careers, along with growing concerns about scientific rigor and integrity, misinformation, and transparency. Protecting the foundations of science, including rigorous peer review, collaboration, open exchange of ideas, and sustained investment in research and workforce development remains essential to future discovery. ASN has consistently championed evidence-based nutrition and will continue to advocate for rigorous, transparent, and trusted science.
During NUTRITION 2026, we also celebrated the people who make our Society exceptional. We remembered members of our community who passed away during the past year, whose scientific achievements, mentorship, and dedication have helped shape our field and will continue to influence future generations. We recognized the second cohort of 69 Excellence in Nutrition Fellows for their outstanding professional achievements and significant contributions to nutrition science, education, and practice. Together with ASN Foundation Chair Paul Coates, I also had the privilege of recognizing the 21 members of the Class of 2026 Distinguished Fellows, who were formally inducted during the Fellows Lunch. Distinguished Fellow is ASN's highest honor, recognizing members with more than 30 years of dedicated service to the Society whose careers have demonstrated sustained excellence and made enduring contributions to nutrition science. We also celebrated our members with more than 50 years of membership and our past presidents, whose leadership, scholarship, and commitment have helped strengthen our Society, our community, and nutrition science.
Despite the challenges we face, I remain optimistic about the future of our field. Through our continued innovation, creativity, persistence, and dedication to evidence-based nutrition science, we will continue advancing knowledge and discovery, mentoring emerging scientists, improving patient care, and moving nutrition science forward to impact public health.
That commitment to excellence is also reflected in ASN's four journals, all of which achieved increases in their Impact Factors this year: Advances in Nutrition, The Journal of Nutrition, Current Developments in Nutrition, and The American Journal of Clinical Nutrition. These achievements are more than performance metrics. They reflect the strength of peer review and the trust placed in scientific rigor, which are essential to improving human nutrition and health and informing policy. Continued progress is only achieved through trust and collaboration. Our field is too complex and multidisciplinary for any one researcher, institution, discipline, or sector to address alone.
Partnerships and collaborations remain central to ASN's mission, and NUTRITION 2026 demonstrated the value of bringing people together to share ideas, learn from one another, build connections, and support the next generation of nutrition scientists and educators. I am so grateful to the Scientific Program Committee, led by Cristina Palacios, PhD, FASN, and Raz Shaikh, PhD, FASN, and to all of the committee members for developing a first-class scientific program that featured more than 2,000 scientific presentations spanning basic, clinical, translational, and population science over four days.
A great way to start the meeting was the Opening Session, "Dietary Guidance at a Crossroads: Science, Practice, and Innovation," chaired by Johanna Dwyer, DSc, RD, DFASN, a pioneer and one of the most respected voices in our field, as well as a Distinguished Fellow, past ASN President, and member of the National Academy of Medicine. The session explored the science that informs dietary guidance, the processes and challenges of translating recommendations into practice, and opportunities to strengthen dietary guidance moving forward. Speakers included members of previous Dietary Guidelines Advisory Committees, Sarah Booth, PhD, Hollie Raynor, PhD, RD, LDN, DFASN, and Bruce Y. Lee, MD, MBA, who engaged with questions and perspectives from the audience as well as questions submitted in advance of the meeting. The discussion reflected the shared commitment of the panel and audience to advance dietary guidance and emphasized the importance of transparent and constructive dialogue in strengthening both the science and the process of developing dietary guidance.
Other highlights included my Presidential Symposium, "Connect with the Fed" sessions, award lectures, flash talks and poster sessions, professional development activities, networking events for students and early career professionals, and daily ASN event summaries featuring video messages from leaders in academia, government, and organizations across the United States and around the world. The spirit of scientific rigor, interdisciplinary collaboration, workforce development, and mentorship was evident throughout the program.
For the first time at an ASN NUTRITION meeting, the Presidential Symposium focused on "One Health in a Global Context: At the Crossroads of Food Systems, Nutrition, and Human Health." The session gathered global leaders in One Health, food systems, and community impact. Keynote speakers Ismahane Elouafi, PhD, Executive Managing Director of the Consultative Group on International Agricultural Research (CGIAR), and Tahmeed Hamed, PhD, Executive Director of the International Centre for Diarrhoeal Disease Research, Bangladesh (icddr,b), both recognized among TIME's 100 Most Influential People of 2025, shared perspectives on how climate-resilient agriculture, diversified food systems, and locally driven solutions can improve diets and health outcomes, particularly for women and children living in climate-stressed and food-insecure settings.
The NUTRITION 2026 program was comprehensive and transdisciplinary, showcasing rigorous and energizing science across a broad range of topics. The breadth and complexity of the science presented reminded us that meaningful progress requires collaboration, creativity, and a willingness to learn from one another while mentoring the next generation of nutrition scientists. Some of the most meaningful connections happen beyond the formal sessions - through poster presentations, hallway discussions, and informal exchanges. I am so grateful for ASN's annual meetings because they have opened doors to collaborations that have shaped and catalyzed my own scientific journey. These connections and learning experiences are what make the NUTRITION meetings so special. It is the gathering of the nutrition community to build collaborations, share knowledge, and mentor one another that is ultimately what advances nutrition science and improves health.
2025-2026 Presidential Report
Presidential Vision
My presidential vision was to expand and strengthen ASN's reach and impact through global partnerships and a One Health approach that connects nutrition with food systems, agriculture, and health.
My priorities were to:
1. Expand ASN's leadership role in advocacy, policy, and education in the United States and globally to support its members.
2. Broaden the scope of nutrition through the transdisciplinary lens of One Health.
3. Advance ASN's global connections and partnerships.
4. Organize regional conferences and workshops on specific topics related to basic and translational nutrition.
Goal 1. Expand ASN's leadership role in advocacy, policy, and education
ASN membership reached a record-breaking number of over 9,000 members. This growth was supported in part through partnerships with the Academic Nutrition Departments and Programs (ANDP) and American Society for Nutrition Foundation (ASNF) Presidential Student Scholarships, as well as global partnerships.
At the policy level, ASN proactively responded to various proposed federal policies, shared ASN's expertise with federal agencies, including the National Institutes of Health (NIH) and the U.S. Department of Agriculture (USDA), and led the Friends of ONR coalition in advocating for a historic increase in funding for the NIH Office of Nutrition Research (ONR) in Fiscal Year 2026.
Goal 2. Broaden the scope of nutrition through the transdisciplinary lens of One Health
I worked to advance One Health as a framework for connecting nutrition with food systems, agriculture, environmental health, and human health.
Key activities included:
* Co-editing a special issue on "Advancing One Health" for The Journal of Nutrition with Ismahane Elouafi, PhD, and Ron L. Cook, DO, MBA.
* Presenting on One Health, Food Systems, and Nutrition at international and regional meetings including the International Union of Nutritional Sciences (IUNS)-International Congress of Nutrition (ICN) in Paris; the Moroccan Society for Nutrition, Health and Environment meeting; and the Asian American Nutrition & Health Summit 2026, organized by the Asian Americans and Pacific Islanders Member Interest Group within the Academy of Nutrition and Dietetics.
* Highlighting Global One Health, Food Systems, and Nutrition during the NUTRITION 2026 Presidential Symposium, with additional abstracts addressing One Health.
* Exploring opportunities for ASN to partner with the North America One Health University Network through my role on its steering committee.
Goal 3. Advance ASN's global connections and partnerships
A major focus of my presidency was strengthening ASN's global presence and developing partnerships that support nutrition science, evidence-based nutrition, knowledge exchange, capacity building, and opportunities for early career professionals and student members. Progress included:
* Established a partnership with the Moroccan Society for Nutrition, Health and Environment (SMNSE) with a Memorandum of Understanding (MOU) signed in December 2025.
* Advanced an MOU with the Emirates Nutrition Association (ENA) to discuss co-sponsorship of leadership workshops and scientific conferences.
* Formalized a strategic alliance with The Obesity Society (TOS) in June 2026.
* Initiated discussions about additional partnerships with the Society for Nutrition Education and Behavior (SNEB), the American Society for Parenteral and Enteral Nutrition (ASPEN), and the International Society for the Study of Fatty Acids and Lipids (ISSFAL).
* Developed a strategic alliance with the National Academies of Sciences, Engineering, and Medicine (NASEM) Food, Nutrition, and Agriculture (FNA) Program Area, which held special sessions during NUTRITION 2026 to update ASN members and attendees on recent restructuring and priorities.
* Expanded engagement with global organizations through meetings, conferences, and discussions about potential partnerships, including the International Atomic Energy Agency (IAEA), CGIAR, the Food and Agriculture Organization (FAO) of the United Nations, the World Health Organization (WHO), the Federation of African Nutrition Societies (FANUS), Nutrition Society of South Africa (NSSA), and North American Chinese Association for Nutrition (NACAN).
These partnership activities expanded ASN's visibility and created opportunities to advance nutrition science, evidence-based nutrition, mentoring, education, and professional development.
Goal 4. Organize regional conferences and workshops
A key goal was to re-engage more basic and translational scientists in ASN and expand membership and collaboration through topical conferences and workshops.
ASN engaged with the ANDP community for co-sponsored regional conferences, including co-sponsoring the 22nd Annual Russell Klein Nutrition Research Symposium, held at The Ohio State University on March 31, 2026.
Additional discussions are underway with partner organizations, including SMNSE, ENA, and TOS, to develop regional and global conferences and scientific sessions or workshops focused on topics of shared interest.
Other Important ASN-supported Initiatives
In addition to these presidential priorities, several other important initiatives advanced during the year. These included the LANTERN (Laboratory Animal Nutrition Taskforce for an Education and Research Network) proposed action plan focused on rigor in the design of animal diets, continued partnership and collaboration with ASNF planning for the ASN Centennial in 2028, and record-breaking engagement among Sustaining Partners.
We also celebrated important advances in clinical nutrition including:
* Establishment of a new Physician Nutrition GEM (Group Engaging Members).
* The WHO New ICD (International Classification of Diseases version 11) Code for Undernutrition in Clinical Settings for Adults.
* Continued collaboration with the National Board of Physician Nutrition Specialists (NBPNS), who ASN partnered with to gain approval of a new Centers for Medicare & Medicaid Services (CMS) physician specialty code which will allow Physician Nutrition Specialists to get reimbursement for their services starting on October 1, a huge professional and policy win for Physician Nutrition Specialists.
Together, these accomplishments strengthen the role of ASN and its affiliated organizations in advancing clinical nutrition and create new opportunities to engage physicians in nutrition science and ASN.
Listening to Our Members
ASN's 2026 member survey provided valuable insight into the needs and priorities of our community. Members identified nutrition meetings, ASN journals, networking, and opportunities to contribute to the field among the most valued aspects of membership.
Members also identified challenges, including research funding, publishing costs, misinformation, policy and regulatory barriers. Early career members highlighted additional needs, including finding mentors, building professional networks, identifying collaborators, and job hunting.
Overall, satisfaction with the ASN membership experience remained high, although needs and perceived benefits varied across different career stages. Based on this feedback, ASN staff are developing strategies to strengthen engagement with current members, recruit new members, and address concerns and priorities identified through the survey.
A Final Note
I am grateful for the opportunity to serve as ASN President and for the dedication of our members, volunteer leaders, and staff throughout the past year. Together, we have strengthened ASN's reach and impact, built new global partnerships, advanced One Health, and supported our growing community. I am confident that ASN will build on this progress to advance nutrition science and improve health in the years ahead.
I would like to add special thanks to John Courtney, Ph.D., ASN's Chief Executive Officer for his leadership and support and his collaborative work with ASN leaders, staff, partners and members. No presidential vision would be achieved without John and our highly dedicated staff who in fact are the ones realizing presidential visions time after time and serve the nutrition community to advance science and impact public health.
I am very grateful to thank my family for their unconditional support, and especially my husband for being a great entertainer and first man! Many thanks to Sophia Pena, for her amazing support throughout my presidency and in my regular job!
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Original text here: https://nutrition.org/a-presidential-farewell-reflections-and-gratitude-from-naima-moustaid-moussa/
[Category: Health Care]
AARP Michigan Poll: Older Voters Critical Demographic in Narrow Senate, Governor Races
WASHINGTON, Aug. 21 -- AARP issued the following news release on Aug. 20, 2026:
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New AARP Michigan Poll: Older Voters Critical Demographic in Narrow Senate, Governor Races
Voters over 50, who make up roughly half of Michigan's swing voters, have rising prices top of mind in the leadup to November's election
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Today, AARP released new polling highlighting the decisive role that voters 50 and older will play in Michigan's tight gubernatorial and Senate races this fall - as well as the top issues that will be driving their vote.
Older Michiganders are a critical voting bloc, consistently ... Show Full Article WASHINGTON, Aug. 21 -- AARP issued the following news release on Aug. 20, 2026: * * * New AARP Michigan Poll: Older Voters Critical Demographic in Narrow Senate, Governor Races Voters over 50, who make up roughly half of Michigan's swing voters, have rising prices top of mind in the leadup to November's election - Today, AARP released new polling highlighting the decisive role that voters 50 and older will play in Michigan's tight gubernatorial and Senate races this fall - as well as the top issues that will be driving their vote. Older Michiganders are a critical voting bloc, consistentlyshowing up to the polls and remaining highly engaged in elections across the state. Voters 50 and older accounted for about 60% of Michigan's electorate in the 2022 midterms. AARP's research suggests that this trend is likely to continue: 86% of voters 50-plus are extremely motivated to vote, compared with 71% of voters under 50. 50+ swing voters make up 8% of Michigan's electorate - roughly half of the state's total swing voters overall - emphasizing how critical this block will be for candidates looking to gain an edge in the runup to November.
"Older voters are a critically important voting demographic that are going to be the deciding bloc in this election, and they're looking for leaders who can speak to the issues they care about," said Nancy LeaMond, AARP Executive Vice President and Chief Advocacy Officer. "Concerns like affordability, Social Security and Medicare should be front and center for candidates competing for their vote."
In the race for Senate, Democrat Abdul El-Sayed holds a razor-thin 48% to 47% advantage over Republican Mike Rogers statewide, with just 5% undecided. There are differences by age, with El-Sayed ahead among voters under 50 by 14-points, and Rogers ahead with voters 50-plus by 9-points. Swing voters 50-plus, who do not vote straight party ticket, favor Rogers by 33-points.
In a close governor's race Democrat Jocelyn Benson leads Republican John James by a narrow 49% to 44% among likely voters statewide. Among voters 50-plus, however, James holds a slight 48% to 47% advantage over Benson. Benson leads among Swing voters 50-plus by 28-points, a net 61-point partisan difference with this group compared to the Senate race.
"This is a close race, and older voters in Michigan are paying attention and ready to make their voices heard," said Paula D. Cunningham, AARP Michigan State Director. "They're looking at what's happening right in their own households and communities. Prices are going up, they want to know that Social Security and Medicare will be there when they need them, and here in Michigan, they want to see action on things like cryptocurrency kiosk fraud and stronger oversight of data center development. At the end of the day, folks want leaders who understand what they're dealing with and will work on the issues that matter in their everyday lives."
AARP's polling found that affordability is the top issue for voters 50-plus, followed by Social Security and Medicare.
Among voters age 50-plus:
* 86% say Social Security is an important issue when deciding their vote, and 93% are more likely to support a candidate who will make sure workers receive the Social Security benefits they earned.
* 77% say Medicare is an important voting issue, and 86% are more likely to support a candidate who would expand Medicare's ability to negotiate prescription drug prices.
* 75% support requiring local communities to permit more accessory dwelling units (ADUs), a proposal aimed at helping address Michigan's affordable housing shortage.
AARP commissioned the bipartisan polling team of Fabrizio Ward (R) and Impact Research (D) to conduct the survey of likely Michigan voters. This is the fourth poll in AARP's 2026 battleground polling series, following surveys of Arizona, Ohio and Georgia. The firms interviewed 877 likely voters statewide. The survey was done between August 9-11, 2026. The interviews were conducted via live interviewer on cell phone (40%) and landline (15%), as well as SMS-to-web (45%). The sample was randomly drawn from the Michigan voter list. The margin of sampling error at the 95% confidence level for the 877 statewide sample is +-3.3%.
View the full survey results at www.aarp.org/mi2026voterpoll and more information on our poll at www.aarp.org/MIpoll. Additional information about AARP's 2026 battleground polling series is available at www.aarp.org/voterpolls2026.
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About AARP
AARP is the nation's largest nonprofit, nonpartisan organization dedicated to empowering people 50 and older to choose how they live as they age. With a nationwide presence, AARP strengthens communities and advocates for what matters most to the 125 million Americans 50-plus and their families: health and financial security, and personal fulfillment. AARP also produces the nation's largest-circulation publications: AARP The Magazine and the AARP Bulletin. To learn more, visit aarp.org, aarp.org/espanol or follow @AARP, @AARPLatino and @AARPadvocates on social media.
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Original text here: https://www.aarp.org/press/releases/2026-08-20-New-AARP-Michigan-Poll-Older-Voters-Critical-Demographic-in-Narrow-Senate-Governor-Races/
[Category: Sociological]
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New AARP Michigan Poll: Older Voters Critical Demographic in Narrow Senate, Governor Races
Voters over 50, who make up roughly half of Michigan's swing voters, have rising prices top of mind in the leadup to November's election
-
Today, AARP released new polling highlighting the decisive role that voters 50 and older will play in Michigan's tight gubernatorial and Senate races this fall - as well as the top issues that will be driving their vote.
Older Michiganders are a critical voting bloc, consistently ... Show Full Article WASHINGTON, Aug. 21 -- AARP issued the following news release on Aug. 20, 2026: * * * New AARP Michigan Poll: Older Voters Critical Demographic in Narrow Senate, Governor Races Voters over 50, who make up roughly half of Michigan's swing voters, have rising prices top of mind in the leadup to November's election - Today, AARP released new polling highlighting the decisive role that voters 50 and older will play in Michigan's tight gubernatorial and Senate races this fall - as well as the top issues that will be driving their vote. Older Michiganders are a critical voting bloc, consistentlyshowing up to the polls and remaining highly engaged in elections across the state. Voters 50 and older accounted for about 60% of Michigan's electorate in the 2022 midterms. AARP's research suggests that this trend is likely to continue: 86% of voters 50-plus are extremely motivated to vote, compared with 71% of voters under 50. 50+ swing voters make up 8% of Michigan's electorate - roughly half of the state's total swing voters overall - emphasizing how critical this block will be for candidates looking to gain an edge in the runup to November.
"Older voters are a critically important voting demographic that are going to be the deciding bloc in this election, and they're looking for leaders who can speak to the issues they care about," said Nancy LeaMond, AARP Executive Vice President and Chief Advocacy Officer. "Concerns like affordability, Social Security and Medicare should be front and center for candidates competing for their vote."
In the race for Senate, Democrat Abdul El-Sayed holds a razor-thin 48% to 47% advantage over Republican Mike Rogers statewide, with just 5% undecided. There are differences by age, with El-Sayed ahead among voters under 50 by 14-points, and Rogers ahead with voters 50-plus by 9-points. Swing voters 50-plus, who do not vote straight party ticket, favor Rogers by 33-points.
In a close governor's race Democrat Jocelyn Benson leads Republican John James by a narrow 49% to 44% among likely voters statewide. Among voters 50-plus, however, James holds a slight 48% to 47% advantage over Benson. Benson leads among Swing voters 50-plus by 28-points, a net 61-point partisan difference with this group compared to the Senate race.
"This is a close race, and older voters in Michigan are paying attention and ready to make their voices heard," said Paula D. Cunningham, AARP Michigan State Director. "They're looking at what's happening right in their own households and communities. Prices are going up, they want to know that Social Security and Medicare will be there when they need them, and here in Michigan, they want to see action on things like cryptocurrency kiosk fraud and stronger oversight of data center development. At the end of the day, folks want leaders who understand what they're dealing with and will work on the issues that matter in their everyday lives."
AARP's polling found that affordability is the top issue for voters 50-plus, followed by Social Security and Medicare.
Among voters age 50-plus:
* 86% say Social Security is an important issue when deciding their vote, and 93% are more likely to support a candidate who will make sure workers receive the Social Security benefits they earned.
* 77% say Medicare is an important voting issue, and 86% are more likely to support a candidate who would expand Medicare's ability to negotiate prescription drug prices.
* 75% support requiring local communities to permit more accessory dwelling units (ADUs), a proposal aimed at helping address Michigan's affordable housing shortage.
AARP commissioned the bipartisan polling team of Fabrizio Ward (R) and Impact Research (D) to conduct the survey of likely Michigan voters. This is the fourth poll in AARP's 2026 battleground polling series, following surveys of Arizona, Ohio and Georgia. The firms interviewed 877 likely voters statewide. The survey was done between August 9-11, 2026. The interviews were conducted via live interviewer on cell phone (40%) and landline (15%), as well as SMS-to-web (45%). The sample was randomly drawn from the Michigan voter list. The margin of sampling error at the 95% confidence level for the 877 statewide sample is +-3.3%.
View the full survey results at www.aarp.org/mi2026voterpoll and more information on our poll at www.aarp.org/MIpoll. Additional information about AARP's 2026 battleground polling series is available at www.aarp.org/voterpolls2026.
* * *
About AARP
AARP is the nation's largest nonprofit, nonpartisan organization dedicated to empowering people 50 and older to choose how they live as they age. With a nationwide presence, AARP strengthens communities and advocates for what matters most to the 125 million Americans 50-plus and their families: health and financial security, and personal fulfillment. AARP also produces the nation's largest-circulation publications: AARP The Magazine and the AARP Bulletin. To learn more, visit aarp.org, aarp.org/espanol or follow @AARP, @AARPLatino and @AARPadvocates on social media.
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Original text here: https://www.aarp.org/press/releases/2026-08-20-New-AARP-Michigan-Poll-Older-Voters-Critical-Demographic-in-Narrow-Senate-Governor-Races/
[Category: Sociological]