One of the most effective advocacy tools of the CFA Institute Washington office is to write comment letters on regulatory proposals and then leverage those letters for blogs and for conversations with regulators, Hill staffers, and the media.

This memo describes what we do, why it is important, and how to measure our impact.

Comment letters contribute to, and can help shape, the public debate on proposals by the US Securities and Exchange Commission (SEC), the Department of Labor, and other regulatory agencies and standard-setters. Specifically, comment letters can have an impact in the following ways:

■ Impact on the stakeholder community.

■ Impact on SEC deliberations.

■ Impact on the public debate.

■ Impact of our presence and branding.

Occasionally, the SEC makes reference to our comment letters or repeats particular arguments attributed to us. Such references have a multiplier effect, magnifying our influence in the following ways:

■ They show that the regulator takes our position seriously and considers it in its rulemaking deliberations.

■ They signal to the public the quality and intellectual rigor of our work.

■ They give us an important metric by which to measure our impact.