Disclosure Standards

Section III. of the AAPOR Code of Professional Ethics & Practice (April 2021) specifies:

III. Standards for Disclosure

Broadly defined, research on public opinion can be conducted using a variety of quantitative and qualitative methodologies, depending on the research questions to be addressed and available resources. Accordingly good professional practice imposes the obligation upon all public opinion and survey researchers to disclose sufficient information about how the research was conducted to allow for independent review and verification of research claims, regardless of the methodology used in the research. Full and complete disclosure for items listed in Section A will be made at the time results are released, either publicly or to a research client, as the case may be. As detailed below, the items listed in Section B, if not immediately available, will be released within 30 days of any request for such materials. If the results reported are based on multiple samples or multiple modes, the preceding items (as applicable) will be disclosed for each.

A. Items for Immediate Disclosure

  • Data Collection Strategy:  Describe the data collection strategies employed (e.g. surveys, focus groups, content analyses).
  • Who Sponsored the Research and Who Conducted It . Name the sponsor of the research and the party(ies) who conducted it. If the original source of funding is different than the sponsor, this source will also be disclosed.
  • Measurement Tools/Instruments. Measurement tools include questionnaires with survey questions and response options, show cards, vignettes, or scripts used to guide discussions or interviews. The exact wording and presentation of any measurement tool from which results are reported as well as any preceding contextual information that might reasonably be expected to influence responses to the reported results and instructions to respondents or interviewers should be included. Also included are scripts used to guide discussions and semi-structured interviews and any instructions to researchers, interviewers, moderators, and participants in the research. Content analyses and ethnographic research will provide the scheme or guide used to categorize the data; researchers will also disclose if no formal scheme was used.
  • Population Under Study. Survey and public opinion research can be conducted with many different populations including, but not limited to, the general public, voters, people working in particular sectors, blog postings, news broadcasts, an elected official’s social media feed. Researchers will be specific about the decision rules used to define the population when describing the study population, including location, age, other social or demographic characteristics (e.g., persons who access the internet), time (e.g., immigrants entering the US between 2015 and 2019). Content analyses will also include the unit of analysis (e.g., news article,  social media post) and the source of the data (e.g., Twitter, Lexis-Nexis).
  • Explicitly state whether the sample comes from a frame selected using a probability-based methodology (meaning selecting potential participants with a known non-zero probability from a known frame) or if the sample was selected using non-probability methods (potential participants from opt-in, volunteer, or other sources).
  • If a frame, list, or panel is used, the description should include the name of the supplier of the sample or list and nature of the list (e.g., registered voters in the state of Texas in 2018, pre-recruited panel or pool).
  • If a frame, list, or panel is used, the description should include the coverage of the population, including describing any segment of the target population that is not covered by the design.
  • For surveys, focus groups, or other forms of interviews, provide a clear indication of the method(s) by which participants were contacted, selected, recruited, intercepted, or otherwise contacted or encountered, along with any eligibility requirements and/or oversampling.
  • Describe any use of quotas.
  • Include the geographic location of data collection activities for any in-person research.
  • For content analysis, detail the criteria or decision rules used to include or exclude elements of content and any approaches used to sample content. If a census of the target population of content was used, that will be explicitly stated.
  • Provide details of any strategies used to help gain cooperation (e.g., advance contact, letters and scripts, compensation or incentives, refusal conversion contacts) whether for participation in a survey, group, panel, or for participation in a particular research project. Describe any compensation/incentives provided to research subjects and the method of delivery (debit card, gift card, cash).
  • Method(s) and Mode(s) of Data Collection. Include a description of all mode(s) used to contact participants or collect data or information (e.g., CATI, CAPI, ACASI, IVR, mail, Web for survey; paper and pencil, audio or video recording for qualitative research, etc.) and the language(s) offered or included. For qualitative research such as in-depth interviews and focus groups, also include length of interviews or the focus group session.
  • Dates of Data Collection.  Disclose the dates of data collection (e.g., data collection from January 15 through March 10 of 2019). If this is a content analysis, include the dates of the content analyzed (e.g., social media posts between January 1 and 10, 2019).
  • Sample Sizes (by sampling frame if more than one frame was used) and (if applicable) Discussion of the Precision of the Results .
  • Provide sample sizes for each mode of data collection (for surveys include sample sizes for each frame, list, or panel used).
  • For probability sample surveys, report estimates of sampling error (often described as “the margin of error”) and  discuss whether or not the reported sampling error or statistical analyses have been adjusted for the design effect due to weighting, clustering, or other factors.
  • Reports of non-probability sample surveys will only provide measures of precision if they are defined and accompanied by a detailed description of how the underlying model was specified, its assumptions validated, and the measure(s) calculated.
  • If content was analyzed using human coders, report the number of coders, whether inter-coder reliability estimates were calculated for any variables, and the resulting estimates.
  • How the Data Were Weighted . Describe how the weights were calculated, including the variables used and the sources of the weighting parameters.
  • How the Data Were Processed and Procedures to Ensure Data Quality. Describe validity checks, where applicable, including but not limited to whether the researcher added attention checks, logic checks, or excluded respondents who straight-lined or completed the survey under a certain time constraint, any screening of content for evidence that it originated from bots or fabricated profiles, re-contacts to confirm that the interview occurred or to verify respondent’s identity or both, and measures to prevent respondents from completing the survey more than once. Any data imputation or other data exclusions or replacement will also be discussed. Researchers will provide information about whether any coding was done by software or human coders (or both); if automated coding was done, name the software and specify the parameters or decision rules that were used.
  • A General Statement Acknowledging Limitations of the Design and Data Collection . All research has limitations and researchers will include a general statement acknowledging the unmeasured error associated with all forms of public opinion research.

B. Additional Items for Disclosure. After results are reported, we will make the following items available within 30 days of any request for such materials:

  • Procedures for managing the membership, participation, and attrition of the panel, if a pool, panel, or access panel was used. This should be disclosed for both probability and non-probability surveys relying on recruited panels of participants.
  • Methods of interviewer or coder training and details of supervision and monitoring of interviewers or human coders. If machine coding was conducted, include a description of the machine learning involved in the coding.
  • Details about screening procedures, including any screening for other surveys or data collection that would have made sample or selected members ineligible for the current data collection (e.g., survey, focus group, interview) will be disclosed (e.g., in the case of online surveys if a router was used).
  • Any relevant stimuli, such as visual or sensory exhibits or show cards. In the case of surveys conducted via self-administered computer-assisted interviewing, providing the relevant screen shot(s) is strongly encouraged, though not required.
  • Summaries of the disposition of study-specific sample records so that response rates for probability samples and participation rates for non-probability samples can be computed. If response or cooperation rates are reported, they will be computed according to AAPOR Standard Definitions. If dispositions cannot be provided, explain the reason(s) why they cannot be disclosed, and this will be mentioned as a limitation of the study.
  • The unweighted sample size(s) on which one or more reported subgroup estimates are based.
  • Specifications adequate for replication of indices or statistical modeling included in research reports.

C. Access to Datasets

Reflecting the fundamental goals of transparency and replicability, AAPOR members share the expectation that access to datasets and related documentation will be provided to allow for independent review and verification of research claims upon request. In order to protect the privacy of individual respondents, such datasets will be de-identified to remove variables that can reasonably be expected to identify a respondent. Datasets may be held without release for a period of up to one year after findings are publicly released to allow full opportunity for primary analysis. Those who commission publicly disseminated research have an obligation to disclose the rationale for why eventual public release or access to the datasets is not possible, if that is the case.

D. AAPOR Standards Complaint

If any of our work becomes the subject of a formal investigation of an alleged violation of this Code, undertaken with the approval of the AAPOR Executive Council, we will provide additional information on the research study in such detail that a fellow researcher would be able to conduct a professional evaluation of the study.

Disclosure FAQs

Are there surveys for which disclosure is not required.

Yes. The disclosure requirement applies only to surveys for which results are released to the public.

I am not an AAPOR member. Am I obligated to disclose the methods used in surveys that I conduct, as called for in the Code?

Yes. The AAPOR Code represents ethical standards that apply to all public opinion researchers. If a complaint of non-disclosure is received, AAPOR can and will censure researchers (and research companies) who fail to disclose their methods as specified in the AAPOR Code, whether or not the individuals are AAPOR members.

Our press agent [or my editor] says there is no room in the press release [or the abstract/presentation/journal article] for all the methods information called for in the Standards for Minimal Disclosure. Is it a violation to publish or present results without these details?

No. AAPOR recognizes that reports about research take many different forms, and that inclusion of all the methods information is not always appropriate. The Code prescribes that researchers will include this information in “any report of research results,” or that they will “make [it] available when that report is released.” In most cases, this means that the researcher will prepare a detailed methodological appendix as a part of a complete research report. Summaries and shorter forms of reports can then refer to the full report as a source for the details of the method, and when such reference is made, the report is taken as “including” the details. The description of method can also be prepared as a separate memo or document, which can be made available in printed or electronic form, for example, by posting on a website. Good practice dictates that public research reports should indicate, whenever practical, where the description of method can be obtained. In any case, the researcher is required to disclose the information listed in the Standards for Minimal Disclosure upon request from any member of the public.

We’ve released some results from our survey, but the questionnaire includes some questions for which we don’t wish to release results. Do we need to disclose the wording of those questions?

Not necessarily. You can meet the requirement for release of question wording (§III.2) by disclosing the wording of only those questions for which results were released, along with the text of any preceding instruction, explanation to the interviewer or respondents, or previous questions that might reasonably be expected to affect the response.

Do I have to acknowledge the existence of questions for which no results are released?

Not necessarily. Note, however, that you do have to release the wording of introductions and instructions that could affect the responses to released questions. Even if these materials mention or imply the existence of the unreleased questions or items, they would still need to be disclosed if they could reasonably affect any of the released questions. Also, if the presence in the survey instrument of the unreleased questions could reasonably be expected to influence the responses to the questions for which results are released, then the existence of those questions must be acknowledged and the text of those questions ought to be released as well, in the interest of full disclosure. In general, it is best to place questions for which you do not intend to release results so that they follow the questions designed for release, so that such effects will be minimized.

One of my political enemies [or commercial rivals] has asked me to disclose details of our survey. This person is going to use the materials to try to make us look bad. Do I need to disclose my survey methods to someone like that?

Yes. The Standards for Minimum Disclosure apply to requests from any member of the public.

Some aspects of our methodology are proprietary. How can you ask us to release them?

All research firms, organizations and individuals are obligated to make the minimally required disclosures, upon request, for any publicly released survey results. It is permissible to describe proprietary methods in general terms, without necessarily providing all the details that another researcher would need to fully replicate the procedure. For example: “The results for this election poll were weighted according to the respondent’s likelihood of voting, using a proprietary formula based on several questions about voting intention and past voting.”

We run a proprietary series of polls with results that are sold by subscription. We’ve put a few results from our latest survey on our website, so prospective subscribers can see how valuable our research could be for them. Does this obligate us to make the minimally required disclosures about our methods?

Yes, if the posting is on a publicly accessible website. If you are not willing to make these disclosures, then don’t make the results publicly available. Save these teaser results for display in your private or individually targeted sales pitches.

I know the standards call for disclosure, but my firm is under contract with the research sponsor and that contract requires us to keep all details of the survey confidential. What should I do?

Under these circumstances, the obligation to disclose would be upon the research sponsor (i.e., your client), assuming the sponsor has released the survey’s results. Refer requests for disclosure to the research sponsor. The Code addresses this issue specifically at §II.A.3:

We shall inform those for whom we conduct publicly released surveys that AAPOR standards require members to release minimal information about such surveys, and we shall make all reasonable efforts to encourage clients to subscribe to our standards for minimal disclosure in their releases.

If key personnel on the project are AAPOR members, they can avoid any misunderstanding on this point by including language similar to the following in the contract with the client (assuming the client is the Sponsor and the AAPOR members’ firm is in the Consultant role):

Applicability of AAPOR Code to publicly released results.  The Sponsor recognizes that the Consultant’s key personnel are members of the American Association for Public Opinion Research (AAPOR) and are bound to adhere to its Code of Ethics and Professional Practicies. Nothing in this contract shall prevent the Consultant from fulfilling its obligation to ensure disclosure by the Sponsor, or the Consultant, upon request from any member of the public, minimally required information about the survey methods as required by the  AAPOR Code of Ethics and Professional Practices , as amended on April, 2021. The requirements of the AAPOR Standards for Minimal Disclosure (Section III of the Code) will apply only to those survey questions, if any, for which statistical results are publicly released by the Sponsor or the Consultant.

Got a question about disclosure?

Contact the AAPOR Standards Chair or Associate Standards Chair for assistance . As questions and answers accumulate, they may be added to this document.

Disclosure FAQ 4/2021 Code as revised 4/2021

Survey Disclosure Checklist

Participation in AAPOR’s Transparency Initiative involves willingness to provide the items listed below in any reports of survey research results that are publicly released, or to make them publicly available, preferably on the organization’s web site, immediately upon release of that report. These items correspond to the first part of Section III.A of AAPOR’s Code of Professional Ethics and Practices, which was revised in April 2021.

  • Data Collection Strategy
  • Who Sponsored the Research and Who Conducted It
  • Measurement Tools/Instruments
  • Population Under Study
  • Method Used to Generate and Recruit the Sample
  • Method(s) and Mode(s) of Data Collection
  • Dates of Data Collection
  • Sample Sizes (by sampling frame if more than one frame was used) and (if applicable) Discussion of the Precision of the Results
  • How the Data Were Weighted
  • How the Data Were Processed and Procedures to Ensure Data Quality
  • A General Statement Acknowledging Limitations of the Design and Data Collection

For more detailed information on these required items for disclosure, please review the  full checklist.

Approved for posting by AAPOR Council, April, 2021

research report disclosure requirements

2019 Presidential Address from the 74th Annual Conference

David Dutwin May 2019

“Many of you know me primarily as a methodologist.  But in fact, my path to AAPOR had nothing to do with methodology.  My early papers, in fact, wholly either provided criticism of, or underscored the critical value of, public opinion and public opinion polls.

And so in some respects, this Presidential Address is for me, completes a full circle of thought and passion I have for AAPOR, for today I would like to discuss matters pertaining to the need to reconsider, strengthen, and advance the mission of survey research in democracy.

Historically, there has been much to say on the role of public opinion in democracy.   George Gallup summarized the role of polls quite succinctly when he said,  “Without polls, [elites] would be guided only by letters to congressmen, the lobbying of pressure groups, and the reports of political henchmen.”

Further,  Democratic theory notes the critical, if not the pivotal role, of public opinion and democratic practice.   Storied political scientist V.O Key said:  “The poll furnishes a means for the deflation of the extreme claims of pressure groups and for the testing of their extravagant claims of public sentiment in support of their demands.”

Furthermore, surveys provide a critical check and balance to other claims of what the American public demands in terms of policies and their government.   Without polls, it would be all that much harder to verify and combat claims of public sentiment made by politicians, elites, lobbyists, and interest groups.  [“No policy that does not rest upon some public opinion can be permanently maintained.”- Abe Lincoln; “Public opinion is a thermometer a monarch should constantly consult” – Napoleon]

It is sometimes asked whether leaders do consult polls and whether polls have any impact of policy.   The relationship here is complex, but time and again researchers have found a meaningful and significant effect of public opinion, typically as measured by polling, on public policy. As one example, Page and Shapiro explored trends in American public opinion from the 1930s to the 1980s and found no less than 231 different changes in public policy following shifts in public opinion.

And certainly, in modern times around the world, there is recognition that the loss of public opinion would be, indeed, the loss of democracy itself. [“Where there is no public opinion, there is likely to be bad government, which sooner or later, becomes autocratic government.” – Willian Lyon Mackenzie King]

And yet, not all agree.  Some twist polling to be a tool that works against democratic principles.  [“The polls are just being used as another tool for voter suppression.” – Rush Limbaugh]

And certainly, public opinion itself is imperfect, filled with non-attitudes, the will of the crowd, and can often lead to tyranny of the majority, as Jon Stewart nicely pointed out. [“You have to remember one thing about the will of the people: It wasn’t that long ago that we were swept away by the Macarena.” – Jon Stewart]

If these later quotes were the extent of criticism on the role of public opinion and survey research in liberal democracy, I would not be up here today discussing what soon follows in this address.  Unfortunately, however, we live a world in which many of the institutions of democracy and society are under attack.

It is important to start by recognizing that AAPOR is a scientific organization.  Whether you are a quantitative or qualitative researcher, a political pollster or developer of official statistics, a sociologist or a political scientist, someone who works for a commercial entity or nonprofit, we are all survey scientists, and we come together as a great community of scientists within AAPOR, no matter our differences.

And so we, AAPOR, should be as concerned as any other scientific community regarding the current environment where science is under attack, devalued, and delegitimized.  It is estimated that since the 2016 election, the federal policy has moved to censor, or misrepresent, or curtail and suppress scientific data and discoveries over 200 times, according to the Sabin Center at Columbia University.  Not only is this a concern to AAPOR as a community of scientists, but we should be concerned as well on the impact of these attacks on public opinion itself.

Just as concerning is the attack on democratic information, in general.  Farrell and Schneier argue that there are two key types of knowledge in democracy, common and contested.  And while we should be free to argue and disagree with policy choices, our pick of democratic leaders, and even many of the rules and mores that guide us as a society, what is called contested knowledge, what cannot be up for debate is the common knowledge of democracy, for example, the legitimacy of the electoral process itself, or the validity of data attained by the Census, or even more so, I would argue, that public opinion does not tell us what the public thinks.

As the many quotes I provided earlier attest to, democracy is dependent upon a reliable and nonideological measure of the will of the people.  For more than a half century and beyond, survey research been the principal and predominant vehicle by which such knowledge is generated.

And yet, we are on that doorstep where common knowledge is becoming contested.  We are entering, I fear, a new phase of poll delegitimization.  I am not here to advocate any political ideology and it is critical for pollsters to remain within the confines of science.  Yet there has been a sea change in how polls are discussed by the current administration.  To constantly call out polls for being fake is to delegitimize public opinion itself and is a threat to our profession.

Worse still, many call out polls as mere propaganda (see Joondeph, 2018).  Such statements are more so a direct attack on our science, our field, and frankly, the entire AAPOR community.  And yet even worse is for anyone to actually rig poll results.  Perhaps nothing may undermine the science and legitimacy of polling more.

More pernicious still, we are on the precipice of an age where faking anything is possible.  The technology now exists to fake actual videos of politicians, or anyone for that matter, and to create realistic false statements.  The faking of poll results is merely in lockstep with these developments.

There are, perhaps, many of you in this room who don’t directly connect with this.  You do not do political polling.  You do government statistics.  Sociology.  Research on health, on education, or consumer research.  But we must all realize that polling is the tip of the spear.  It is what the ordinary citizen sees of our trade and our science.  As Andy Kohut once noted, it represents all of survey research. [Political polling is the “most visible expression of the validity of the survey research method.“ – Andrew Kohut]

With attacks on science at an all-time high in the modern age, including attacks on the science of surveys; with denigration of common knowledge, the glue that holds democracy together, including denunciation on the reliability of official statistics; with slander on polling that goes beyond deliberation on the validity of good methods but rather attacks good methods as junk, as propaganda, and as fake news; and worse of all, a future that, by all indications, will if anything include the increased frequency of fake polls, and fake data, well, what are we, AAPOR, to do?

We must respond.  We must react.  And, we must speak out.  What does this mean, exactly?  First, AAPOR must be able to respond.  Specifically, AAPOR must have vehicles and avenues of communication and the tools by which it can communicate.  Second, AAPOR must know how to respond.  That is to say, AAPOR must have effective and timely means of responding.  We are in an every minute of the day news cycle.  AAPOR must adapt to this environment and maximize its impact by speaking effectively within this communication environment.  And third, AAPOR must, quite simply, have the willpower to respond.  AAPOR is a fabulous member organization, providing great service to its members in terms of education, a code of ethics, guidelines for best practices and promotions of transparency and diversity in the field of survey research.  But we have to do more.  We have to learn to professionalize our communication and advocate for our members and our field.  There are no such thing as sidelines anymore.  We must do our part to defend survey science, polling, and the very role of public opinion in a functioning democracy.

This might seem to many of you like a fresh idea, and bold new step for AAPOR.  But in fact, there has been a common and consistent call for improved communication abilities, communicative outreach, and advocacy by many past Presidents, from Diane Colasanto to Nancy Belden to Andy Kohut.

Past President Frank Newport for example was and is a strong supporter of the role of public opinion in democracy, underscoring in his Presidential address that quote, “the collective views of the people…are absolutely vital to the decision-making that ultimately affects them.” He argued in his Presidential address that AAPOR must protect the role of public opinion in society.

A number of Past Presidents have rightly noted that AAPOR must recognize the central role of journalists in this regard, who have the power to frame polling as a positive or negative influence on society.  President Nancy Mathiowetz rightly pointed out that AAPOR must play a role in, and even financially support, endeavors to guarantee that journalists’ support AAPOR’s position on the role of polling in society and journalists’ treatment of polls.  And Nancy’s vision, in fact, launched relationship with Poynter in building a number of resources for journalist education of polling.

Past President Scott Keeter also noted the need for AAPOR to do everything it can to promote public opinion research.  He said that “we all do everything we can to defend high-quality survey research, its producers, and those who distribute it.”  But at the same time, Scott noted clearly that, unfortunately, “At AAPOR we are fighting a mostly defensive war.”

And finally, Past President Cliff Zukin got straight to the point in his Presidential address, noting that, quote “AAPOR needs to increase its organizational capacity to respond and communicate, both internally and externally. We need to communicate our positions and values to the outside world, and we need to diffuse ideas more quickly within our profession.”

AAPOR is a wonderful organization, and in my biased opinion, the best professional organization I know.  How have we responded to the call of past Presidents?  I would say, we responded with vigor, with energy, and with passion.  But we are but a volunteer organization of social scientists.  And so, we make task forces.  We write reports.  These reports are well researched, well written, and at the same time, I would argue, do not work effectively to create impact in the modern communication environment.

We have taken one small step to ameliorate this, with the report on polling in the 2016 election, which was publicly released via a quite successful live Facebook video event.  But we can still do better.  We need to be more timely for one, as that event occurred 177 days after the election, when far fewer people were listening, and the narrative was largely already written.  And we need to find ways to make such events have greater reach and impact.  And of course, we need more than just one event every four years.

I have been proud to have been a part of, and even be the chair of, a number of excellent task force reports.  But we cannot, I submit, continue to respond only with task force reports.  AAPOR is comprised of the greatest survey researchers in the world.  But it is not comprised of professional communication strategists, plain and simple.  We need help, and we need professional help.

In the growth of many organizations, there comes a time when the next step must be taken.  The ASA many years ago, for example, hired a full time strategic communications firm.  Other organizations, including the NCA, APSA, and others, chose instead to hire their own full time professional communication strategist.

AAPOR has desired to better advocate for itself for decades.  We recognize that we have to get into the fight, that there are again no more things as sidelines.  And we have put forward a commendable effort in this regard, building educational resources for journalists, and writing excellent reports on elections, best practices, sugging and frugging, data falsification, and other issues.  But we need to do more, and in the context of the world outside of us, we need to speak a language that resonates with journalists, political elites, and perhaps most importantly the public.

I want to stop right here and make it clear, that the return on investment on such efforts is not going to be quick.  And the goal here is not to improve response rates, though I would like that very much!  No, it is not likely that any efforts in any near term reverses trends in nonresponse.

It may very well be that our efforts only slow or at best stop the decline. But that would be an important development.  The Washington Post says that democracy dies in darkness.  If I may, I would argue that AAPOR must say, democracy dies in silence, when the vehicle for public opinion, surveys, has been twisted to be distrusted by the very people who need it most, ordinary citizens.  For the most part, AAPOR has been silent.  We can be silent no more.

This year, Executive Council has deliberated the issues outlined in this address, and we have chosen to act.  The road will be long, and at this time, I cannot tell you where it will lead.  But I can tell you our intentions and aspirations.  We have begun to execute a 5 point plan that I present here to you.

First, AAPOR Executive Council developed and released a request for proposals for professional strategic communication services.  Five highly regarded firms responded.  After careful deliberation and in person meetings with the best of these firms, we have chosen Stanton Communications to help AAPOR become a more professionalized association.  Our goals in the short term are as follows.

We desire to become more nimble and effective at responding to attacks on polls, with key AAPOR members serving as spokespersons when needed, but only after professional development of the messages they will promulgate, approved by Council, and professionalized by the firm.  Stanton brings with it a considerable distribution network of journalists and media outlets.  AAPOR, through its professional management firm Kellen, has access to audio and video services of the National Press Club, and will utilize these services when needed to respond to attacks on polls, and for other communications deemed important by AAPOR Executive Council.

Our plan is to begin small.  We are cognizant of the cost that professional communication can entail, and for now, we have set very modest goals. The first step is to be prepared, and have a plan for, the 2020 election, with fast response options of communication during the campaign, and perhaps most importantly, directly thereafter.

The second element of our plan is to re-envision AAPOR’s role in journalism education.  In short, we believe we need to own this space, not farm it out to any other entity.  We need refreshed educational videos, and many more of them, from explaining response rates to the common criticisms made on the use of horserace polling in the media.

We need to travel.  Willing AAPOR members should be funded to travel and present at journalism conferences, to news rooms, and to journalism schools on an annual basis. AAPOR could as well have other live events, for example a forum on the use of polls in journalism.  There should be a consistent applied effort over time.  The media and journalists are AAPOR’s greatest spokespeople.  By and large, much of our image is shaped through them.

The third element looks at the long game.  And that is, for AAPOR to help in developing civics education on public opinion and the role of public opinion in democracy.  With the help of educational experts, and importantly, tipping our hats to our AAPOR’s Got Talent winner last year, Allyson Holbrook, who proposed exactly this kind of strategy, we believe AAPOR can help develop a curriculum and educational materials and engage with educators to push for the inclusion of this curriculum in primary education.  AAPOR can and should develop specific instructional objectives of civics education by grade and develop a communications plan to lobby for the inclusion of this civics curriculum by educators.

The fourth element is for AAPOR to direct the Transparency Initiative to develop a strategic plan for the next ten years.  We recognize that it is not always the case that polls are executed with best practices.  How does AAPOR respond in these instances?  With a plethora of new sampling approaches and modalities, we believe the TI needs to have a full-throated conversation about these challenges and how AAPOR should handle them.  After all, this too is part of the conversation of AAPOR communication.

Finally, AAPOR should, as past President Tim Johnson called for last year, learn as much as it can about the perceptions of polls in society.  We cannot make effective strategic communication plans without knowing first how they will resonate and know to some degree their expected effectiveness.  Such an effort should continue over time, building both a breadth and depth of understanding.

If this sounds a bit like a wish list, well, you would be right.  For now, the immediate goal for AAPOR and its communication firm is to prepare for 2020 and to take some modest steps toward professionalizing AAPOR’s ability to effectively and quickly communicate and advocate.    Looking toward the future, AAPOR Council has authorized the development of the Ad Hoc Committee on Public Opinion.  This committee will be comprised of AAPOR members dedicated to pushing forward this agenda.

We recognize the potential cost of these endeavors in terms of money and labor, and so in each area, there will be mission leaders on the committee whose goal is to push forward with two goals.  The first is funding.  We cannot and should not fund these endeavors alone.  We will be seeking foundational funding for each of these areas, and are developing a proposal for each specifically.  Perhaps only one area attains funding, perhaps all of them.  No matter, the committee will adjust its goals contingent on the means it has available.

A number of members have already asked to be part of these efforts.  But I call on all of you, the AAPOR membership, to reach out and join the effort as well.  We need people experienced in seeking funding, and people passionate in moving the needle with regard to polling journalism, civics education, and the role of public opinion in democracy.  AAPOR’s secret sauce has always been the passion of its members and we call on you to help.  Please go the link below to tell us you want to join the effort.

Friends and colleagues, one of the many excellent AAPOR task forces already, in fact explored this issue, the task force on polling and democracy and leadership.  They argued that “AAPOR should adopt an increased public presence arguing for the importance of public opinion in a democracy and the importance of rigorous, unbiased, scientific research assessing public opinion.”

It is time we strive to realize these aspirations.  For the good of our association, our field, and our very democracy.  If past efforts by AAPOR volunteers are any indication, we anticipate great success and health in the future of our field and our endeavors.

It has been an honor and a privilege serving as your President. Thank you.”

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ResearchSecurity

In February 2024, the White House Office of Science and Technology Policy (OSTP) issued a memorandum on Policy Regarding Use of Common Disclosure Forms , which outlines guidelines on the use of common disclosure forms for federal agencies to use when evaluating proposals. These will help the government identify conflicts of commitment and potential duplication with the work of foreign governments. OSTP also released Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs . This guidance provides a definition of foreign talent recruitment programs, guidelines for federal employees regarding foreign talent recruitment programs, and guidelines for individuals involved in malign foreign talent recruitment programs in federal projects.

In August 2023, the National Institute of Standards and Technology (NIST) released the " Safeguarding International Science Research Security Framework ," which is designed to enable organizations to implement a mission-focused, integrated, risk-balanced program through the application of research security principles and best practices that fosters the safeguarding of international science while mitigating risks to the integrity of the open collaborative environment. This NIST Framework is a living document and will continue to be updated and improved as its users provide feedback on implementation of review procedures or to address new or emerging risks. This will ensure it is meeting the needs of Research Security practitioners in a dynamic and challenging environment of new threats, risks, and creative solutions.

The National Science Foundation is committed to maintaining the integrity of international scientific collaborations. They have developed resources to enhance research security practices that are reliable and adaptive to emerging and evolving threats. You can find these resources below and visit the NSF Research Security site for more information.

Quick Reference

    Introduction

  • Research Security Background Documents
  • Research Security Actions and Practices
  • White House Documents
  • Documents on Disclosure Requirements and Standardization
  • Documents on Digital Persistent Identifiers (DPIs)
  • Documents on Research Security Programs
  • Risk Assessment and Mitigation
  • Value of Principled International Collaboration
  • Research Security Guidance from International Entities
  • Research Security Guidance from Associations and Societies  

Introduction

Below is a collection of documents for reference collected by the National Science Foundation’s (NSF) Office of the Chief of Research Security Strategy and Policy (OCRSSP) regarding best practices in research security for the academic community. As stated by the NSPM-33 Implementation Guidance, research security is defined as “safeguarding the research enterprise against the misappropriation of research and development to the detriment of national or economic security, related violations of research integrity, and foreign government interference.” 

This research security toolkit is intended to serve as a resource for the academic community to understand initiatives currently underway and rationale for published guidance. Beginning with documents intended to outline key emerging concerns in the fundamental research security ecosystem (see Section I and Section II ) and documents published by the White House (see Section III ), resources are then categorized into seven groups: resources related to disclosure requirements and standardization (see Section IV ); digital persistent identifiers (DPIs) (see Section V ); research security programs (see Section VI ); risk assessment and mitigation (see Section VII ); the value of principled collaboration (see Section VIII ); research security guidance from international entities (see Section IX ); and research security guidance from associations and societies (see Section X ).

I. Research Security Background Documents

  • NSDD-189 – National Security Decision Directive 189 (NSDD-189) (Established in 1985, reaffirmed in 2001 and 2010) Directive Short Description: NSDD-189 remains a cornerstone of the fundamental research enterprise, making a clear distinction between fundamental and classified research and stating that products of fundamental research should remain “remain unrestricted” to the “maximum extent possible.”
  • JASON/NSF – JASON Report on Fundamental Research Security (Dec 2019) Full Report Short Description: “NSF has charged JASON to produce an unclassified report that can be widely disseminated and discussed in the academic community, providing technical or other data about specific security concerns in a classified appendix.” Of the 6 questions NSF charged JASON to answer relevant to openness in fundamental research, principles of scientific openness, areas of fundamental research necessitating more control, controls on information, and best practices researchers can put in place, this report details “the results from the ensuing inquiry, discussions, and debates engaged with NSF, senior university administrators, the intelligence community, law enforcement, and others.” NSF Response to JASON Report Short Description: This document includes NSF’s response to JASON’s nine recommendations on fundamental science and security.
  • The Association of American Universities (AAU), Association of Public and Land-Grant Universities (APLU), Council on Government Relations (COGR) – University Actions to Address Concerns about Security Threats and Undue Foreign Government Influence on Campus (May 2020) Document Short Description: “APLU and AAU have previously identified and shared effective practices universities are employing to ensure the security of research, protect against intellectual property theft and academic espionage, and prevent actions or activities by foreign governments and/or other entities that seek to exert undue foreign government influence or infringe on core academic values (e.g. free speech, scientific integrity, etc.)...The following incorporates new and existing activities universities are pursuing, according to the recent survey collection. We encourage all universities to review these examples and to consider implementing practices that might prove effective on their own campuses to protect against research security threats and undue foreign government.”
  • NSF – Research Security Website Website Short Description: The NSF Research Security website includes updates on research security activities being conducted by the Office of the CRSSP, summaries of issues relevant to foreign interference and risk mitigation, and additional resources for reference.
  • NSF – Webpage on NSTC Research Security Subcommittee, NSPM-33 Implementation Guidance Disclosure Requirements & Standardization Website Short Description: “The National Science and Technology Council (NSTC) Research Security Subcommittee has worked to develop consistent disclosure requirements for use by senior personnel, as well as to develop proposed common disclosure forms for the Biographical Sketch and Current and Pending (Other) Support sections of an application for Federal research and development (R&D) grants or cooperative agreements. NSF has agreed to serve as steward for these common forms as well as for posting and maintenance of the table entitled, NSPM-33 Implementation Guidance Pre- and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending (Other) Support.” This website provides up-to-date information on disclosure requirements.
  • COGR – Matrix of Science & Security Laws, Regulations, and Policies (Sep 2022) Webpage with Matrix Short Description: “COGR has developed a comprehensive chart that summarizes and compares federal laws, regulations, and policies in the area of science and security. The chart is divided into three separate tabs that cover (a) major federal-wide legislation or policy (e.g., National Presidential Security Memorandum 33, CHIPS and Science Act of 2022); (b) agency disclosure requirements for researchers and research institutions; and (c) agency conflict of interest policies. The chart will be updated as new laws, policy and guidance are published."

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II. Research Security Actions and Practices

  • NSF – Former NSF Director Dr. France A. Córdova’s Dear Colleague Letter to the Academic Community (Jul 2019) Letter Short Description: Short Description: This Dear Colleague Letter, addressed to the academic community, identifies emerging risks to the nation’s science and engineering enterprise and identifies actions NSF is undertaking to uphold the values of “openness, transparency, and reciprocal collaboration.”
  • AAU, APLU, COGR – University Actions to Address Concerns about Security Threats and Undue Foreign Government Influence on Campus (May 2020) Document Short Description:
  • NSTC – Recommended Practices for Strengthening the Security and Integrity of America’s Science and Technology Research Enterprise (Jan 2021) Document Short Description: “This document was developed by the Subcommittee on Research Security, in coordination with the National Security Council staff, and was reviewed by JCORE [the Joint Committee on the Research Environment]. The document outlines recommended guidelines for organizations that conduct research.”
  • American Council on Education (ACE) – Letter to ACE Member Presidents and Chancellors Regarding Growing Concerns about Foreign Influence/Interference (May 2019) Letter Short Description: This letter to ACE member Presidents and Chancellors highlights growing concerns regarding foreign influence and foreign interference in the U.S. research environment. In addition to citing steps federal entities are taking to secure the fundamental research environment, the letter offers suggestions and actions institutions can take to further enhance the security of their international partnerships.
  • AAU – Actions Taken to Address Foreign Security Threats, Undue Foreign Interference, and Protect Research Integrity at U.S. Universities (Jun 2022) Document Short Description: This document summarizes “actions that have already been taken or are currently being taken by both universities and federal entities regarding research security.” Sections include 1) actions taken by universities; 2) actions taken by Congress; 3) actions taken by the Executive branch and federal agencies; and 4) existing federal research security requirements.

III. White House Documents

  • National Security Presidential Memorandum on United States Government-Supported Research and Development National Security Policy 33 (NSPM-33) (Jan 2021) Memorandum Short Description: “This memorandum directs action to strengthen protections of United States Government-supported Research and Development (R&D) against foreign government interference and exploitation. The United States Government provides significant support to R&D across a broad spectrum of research institutions and programs conducted both within and outside of the United States and its territories. This R&D, including both basic and applied research, is a key contributor to American science and technology (S&T) innovation and is essential to United States economic and national security.”
  • NSTC – NSPM-33 Implementation Guidance (Jan 2022) Implementation Guidance Short Description: “The purpose of this document is to provide guidance to Federal departments and agencies regarding their implementation of National Security Presidential Memorandum 33 on National Security Strategy for U.S. Government-Supported Research and Development.”

IV. Documents on Disclosure Requirements and Standardization

  • Government Accountability Office (GAO) – Federal Research: Agencies Need to Enhance Policies to Address Foreign Influence (Dec 2020) Report Short Description: “GAO was asked to review federal agency and university COI policies and disclosure requirements. In this report, GAO examines (1) COI policies and disclosure requirements at selected agencies and universities that address potential foreign threats, (2) mechanisms to monitor and enforce policies and requirements, and (3) the views of selected stakeholders on how to better address foreign threats to federally funded research. GAO reviewed laws, regulations, federal guidance, and agency and university COI policies and requirements. GAO also interviewed agency officials, university officials, and researchers.” See full report for information relevant to disclosure requirements and standardization.
  • NSPM-33 (Jan 2021) Memorandum Short Description: For information relevant to disclosure requirements and standardization, see Section 4.
  • NSTC – NSPM-33 Implementation Guidance (Jan 2022) Document Short Description: For information relevant to disclosure requirements and standardization, see pp. 2-7.
  • NSF – NSF Proposal and Award Policies and Procedures Guide (PAPPG) (NSF 22-1) (Oct 2021) Document Short Description: “The PAPPG is comprised of information relating to NSF’s proposal and award process for the assistance programs of NSF.” The PAPPG is designed to set forth NSF’s proposal preparation and submission guidelines, as well as set forth NSF policies and procedures regarding the award, administration, and monitoring of grants and cooperative agreements. For information relevant to disclosure requirements and standardization, see Chapters II.C.1.e, II.C.2.f, and II.C.2.h.
  • NSF – Draft Common Disclosure Forms for the Biographical Sketch and Current and Pending (Other) Support Federal Register Notice NSF Website Short Description: “NSF, on behalf of the National Science and Technology Council's (NSTC) Research Security Subcommittee, is soliciting public comment on common disclosure forms for the Biographical Sketch and Current and Pending (Other) Support sections of a research application. An excel spreadsheet that summarizes all of the data elements that will be collected in both the Biographical Sketch and Current and Pending (Other) Support, as well as their associated attributes, also is included for public comment.” All comments must be received by October 31, 2022, to be assured consideration. For updated information relevant to disclosure requirements and standardization, visit the NSF website.
  • National Institutes of Health (NIH) – Requirements for Disclosure of other Support, Foreign Components, and Conflicts of Interest Website Short Description: “Full transparency in NIH applications and throughout the life of an NIH grant is critical. NIH requires the disclosure of all sources of research support, foreign components, and financial conflicts of interest for senior/key personnel on research applications and awards. NIH uses this information when making its funding decisions to determine if the research being proposed is receiving other sources of funding that could be duplicative, has the necessary time allocation, or if financial interests may affect objectivity in the conduct of the research.” This webpage provides information on applicant and recipient institution responsibilities, a chart on disclosure requirements, and details NIH’s responsibilities in the grant award process. For information relevant to disclosure requirements and standardization, see full webpage.
  • Department of Energy (DOE) – PF 2022-32 Department of Energy Current and Pending Support Disclosure Requirements for Financial Assistance (Jun 2022) Website Financial Assistance Letter Short Description: “Information and guidance regarding the Department of Energy’s (DOE’s) implementation of National Security Presidential Memorandum 33 (NSPM-33) on National Security Strategy for United States Government-Supported Research and Development, issued January 2022 is provided by the attached Financial Assistance Letter.” For information relevant to disclosure requirements and standardization, see the Financial Assistance Letter

V. Documents on Digital Persistent Identifiers (DPIs)

  • NSPM-33 (Jan 2021) Memorandum Short Description: For information relevant to DPIs, see Section 4.
  • NSTC – NSPM-33 Implementation Guidance (Jan 2022) Implementation Guidance Short Description: For information relevant to DPIs, see pp. 8-10.
  • COGR – Summary of NSTC Guidance for Implementing NSPM-33: Provisions Regarding DPIs, Consequences, Information Sharing and Research Programs (Jan 2022) Summary Short Description: “This summary highlights key points of the NSPM-33 Guidance that address the other topics covered by the document: DPIs, consequences, information sharing, and research security programs.” For information relevant to DPIs, see pp. 1-2.

VI. Documents on Research Security Programs

  • NSPM-33 (Jan 2021) Memorandum Short Description: For information relevant to research security programs, see Section 4.
  • NSTC – NSPM-33 Implementation Guidance (Jan 2022) Implementation Guidance Short Description: For information relevant to research security programs, see pp. 18-21.
  • GAO – Federal Research: Agencies Need to Enhance Policies to Address Foreign Influence (Dec 2020) Report Short Description: For information relevant to research security programs, see pp. 25-26.
  • AAU, APLU, COGR – University Actions to Address Concerns about Security Threats and Undue Foreign Government Influence on Campus (May 2020) Document Short Description: For information relevant to research security programs, see pp. 2-5.
  • COGR – Summary of NSTC Guidance for Implementing NSPM-33: Provisions Regarding DPIs, Consequences, Information Sharing and Research Programs (Jan 2022) Summary Short Description: For information relevant to research security programs, see pp. 5-6, 8-9.

VII. Risk Assessment and Mitigation

  • NSF/JASON – JASON Report on Fundamental Research Security (Dec 2019) Full Report Short Description: See full report for information relevant to risk assessment and mitigation. See Section 7.3 for samples of questions that may be used for risk assessment.
  • NSF – Research Security Website Website Short Description: For information relevant to risk assessment and mitigation, see section on “Foreign Interference and Risk Mitigation.”
  • NSTC – Recommended Practices for Strengthening the Security and Integrity of America’s Science and Technology Research Enterprise (Jan 2021) Document Short Description: For information relevant to risk assessment and mitigation, see pp. 14-15, items 18-21.
  • AAU, APLU – Principles and Values to Guide Actions Relevant to Foreign Government Interference in University Research (May 2021) Document Short Description: This document summarizes “fundamental principles and values of the AAU and APLU member institutions that are relevant to their approach to foreign government interference. The goal of articulating these principles and values is to foster protection against foreign government interference without damaging the contributions to national and economic security that the United States derives from the university research enterprise.” The document covers three components: 1) common values of AAU and APLU universities relevant to foreign government interference in research; 2) principles for government actions in protecting and ensuring the future of the U.S. university research enterprise, and 3) principles for universities in responding to foreign government interference. For information relevant to risk assessment and mitigation, see pp. 6-7.
  • ACE – Letter to ACE Member Presidents and Chancellors Regarding Growing Concerns about Foreign Influence/Interference (May 2019) Letter Short Description: For information relevant to risk assessment and mitigation, see pp. 4-7.
  • ACE – Letter to ACE Member Presidents Hosting Confucius Institutes (Jul 2018) Letter Short Description: This letter to ACE member presidents of institutions with Confucius Institutes provides recommendations on how to proactively assess the security of these specific programs, increase transparency, and enhance the security of research with national and economic security implications.

VIII. Value of Principled International Collaboration

  • American Academy of Arts and Sciences (AAAS) – America and the International Future of Science, Challenges for International Scientific Partnerships Initiative (Dec 2020) Report Short Description: “This report takes a broad view of international scientific partnerships, on all scales and levels of formality, and identifies elements that are integral to successful collaboration.” For information relevant to principled international collaboration, see pp. 33-35.

IX. Research Security Guidance from International Entities

  • Australia – “Guidelines to Counter Foreign Interference in the Australian University Sector”, University Foreign Interference Taskforce (Nov 2019, modified in Nov 2021) Guidelines Short Description: “These Guidelines support universities to develop new or examine existing tools, frameworks and resources to use for assessing and mitigating risks from foreign interference, proportionate to risk. They also promote greater consistency across the sector. They offer principle-based and specific advice to universities on how to manage risk in their institution. The advice recognises that risk is not uniform across the sector, and universities may implement additional or existing leading-practice mitigation actions proportionate to their own risks of foreign interference. Universities are encouraged to consider whether the Guidelines can be applied to transnational education business models or offshore campuses, where appropriate.”
  • Australia – Australian Strategic Policy Institute, China Defence Universities Tracker (launched Nov 2019, updated May 2021) Tracker Report Short Description: “The China Defence Universities Tracker is a database of Chinese institutions engaged in military or security-related science and technology research. The updated Tracker – and accompanying report – continue to be a tool that enables universities, governments, the business community and scholars to conduct due diligence as they engage with entities from China…the Tracker should be used to inform due diligence of Chinese institutions, however, the fact that an institution is not included here does not indicate that it should not raise risks or is not involved in defence research. Similarly, entries in the database may not reflect the full range and nature of an institution’s defence and security links.”
  • Canada – Safeguarding Your Research Website Website Short Description: This website provides researchers guidance on how to safeguard their research and innovation, covering topics such as 1) why researchers should safeguard research, 2) who they are at risk from, 3) what risks exist, 4) steps that can be taken to protect research, and more.
  • Denmark – “Guidelines for International Research and Innovation Cooperation” (May 2022) Guidelines Short Description: “These guidelines have been prepared by the Committee on guidelines for international research and innovation cooperation…[and are intended to] help Danish institutions achieve a balanced approach to international cooperation on research and innovation, aiming to reduce ethical, financial and security risks and to protect their own long-term interests within such cooperation.”
  • Global Research Council – Statement of Principles and Practices for Research Ethics, Integrity, and Culture in the Context of Rapid-Results Research (May 2022) Statement Short Description: “This Statement outlines eight principles and practices that frame the collective responsibility of funding agencies; researchers; public and private research organizations (both for- and non-profit); and national governments in ensuring the integrity of rapid-results research. This statement addresses all aspects of national and international research enterprises, from ideation to dissemination and commercialization, and has the potential to strengthen research outcomes.”
  • G7 – Common Values and Principles on Research Security and Research Integrity (June 2022) Paper Short Description: This collaborative paper among G7 members emphasizes “the continuation of a collaborative research system where the importance of all talent – domestic and international – is acknowledged. Openness and security are not contradictory but complementary and mutually reinforcing.” This paper provides the G7’s common vision and principles in research security and integrity; defines important concepts; and describes current activities aimed at addressing existing concerns in the research enterprise.
  • Japan – Policy Directions for Ensuring Research Integrity in Response to New Risks Associated with Increasing Internationalization and Openness of Research Activities (April 2021) Document Short Description: This document outlines steps the Japanese government is taking “in collaboration with researchers, universities, research institutions, and research funding agencies to support [and] autonomously secure the soundness and fairness of research (research integrity) of researchers, universities, and research institutions.” Efforts discussed include initiatives relevant to disclosure and outreach to organizations.
  • New Zealand – Due Diligence Assessments: For Espionage and Foreign Interference Threats (May 2022) Guide Short Description: “This guidance outlines potential Foreign Interference risks to New Zealand business, research, and investment. It has practical approaches to due diligence, including identifying and making informed decisions about potential risks.”
  • Organization for Economic Co-operation and Development (OECD) – OECD Report on Integrity and Security in the Global Research Ecosystem (June 2022) Report Short Description: “This report describes policy initiatives and actions to safeguard national and economic security whilst protecting freedom of inquiry, promoting international research cooperation, and ensuring openness and non-discrimination. It includes examples of actions that are being taken to prevent foreign interference, manage risks, and help ensure trust in science in the future, offering recommendations to help countries develop effective policies to strengthen research security as part of a broader framework of research integrity.”
  • Sweden – Swedish Foundation for International Cooperation in Research and Higher Education (STINT), Responsible Internationalisation: Guidelines for Reflection on International Academic Collaboration (2020) Document Short Description: “The document is intended to serve as support for reflection and as the basis for discussion of strategic decisions on internationalisation. The purpose is to aid researchers, research directors, department heads, and university administration in assessing collaborations and structuring discussions on how the HEI [higher education institution], department or research group should approach international collaboration.”
  • United Kingdom – Website on Trusted Research Website Short Description: Trusted Research, “a campaign to raise awareness of the risks to research collaborations which may occur when working with organisations or research partners with links to nations whose democratic and ethical values are different from our own”, aims to support the integrity of the system of international research collaboration. “Advice has been produced in consultation with the research and university community and is designed to help the U.K.’s world-leading research and innovation sector get the most out of international scientific collaboration whilst protecting intellectual property, sensitive research and personal information.” The U.K. Government’s National Technical Authority for Physical and Personnel Protective Security has developed an interactive website that provides guidance and checklists for academia and industry.

X. Research Security Guidance from Associations and Societies

  • AAU, APLU, COGR – University Actions to Address Concerns about Security Threats and Undue Foreign Government Influence on Campus (May 2020) Document Short Description
  • AAU, APLU – Principles and Values to Guide Actions Relevant to Foreign Government Interference in University Research (May 2021) Document Short Description
  • ACE – Letter to ACE Member Presidents and Chancellors Regarding Growing Concerns about Foreign Influence/Interference (May 2019) Letter Short Description
  • ACE – Letter to ACE Member Presidents Hosting Confucius Institutes (Jul 2018) Letter Short Description
  • Association of American Medical Colleges (AAMC) – Research Security and Foreign Interference at U.S. Academic Institutions Webpage Webpage Short Description: “This page provides background information [on research security and foreign interference], the latest updates on relevant federal government policies and activities, and considerations and resources for institutional leadership, administrators, and researchers as they address this issue on their [campuses].”
  • COGR – Matrix of Science & Security Laws, Regulations, and Policies (Sep 2022) Webpage with Matrix Short Description
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U.S. Government Accountability Office

National Institute of Standards and Technology: Strengthening Disclosure Requirements and Assessing Training Could Improve Research Security

Some foreign governments try to acquire U.S. research and technology dishonestly. Protecting federally funded research from such threats is critical.

The National Institute of Standards and Technology collaborates with foreign and domestic researchers—requiring them to disclose potential conflicts of interest. But NIST doesn't require domestic researchers to disclose as much information as foreign nationals. NIST needs to ensure it can identify research security risks posed by all researchers.

In addition, NIST doesn't evaluate whether staff training on security policies and practices is effective.

We recommended that NIST address these issues.

Summary of NIST’s Process for Reviewing and Hosting Foreign National Associates

process is: gather info, security review, approve/deny, background check, report suspicious activity

What GAO Found

Researchers employed at the National Institute of Standards and Technology (NIST) collaborate on research projects with about 2,500 domestic and foreign national researchers (known as “associates”) each year. The agency also awards grants and cooperative agreements under which extramural (i.e., external) researchers carry out research. While such collaborations are intended to benefit NIST, they may pose security risks. NIST has taken steps to help ensure research security by requiring researchers to disclose information that can help it determine whether they have potential conflicts of interest or commitment.

However, at the time of our review, NIST had not fully implemented federal disclosure requirements as the agency was waiting for the Office of Science and Technology Policy (OSTP) to issue government-wide guidance in two areas:

  • uniform disclosure forms for extramural researchers, and
  • guidelines on foreign talent recruitment programs, which seek to recruit researchers—sometimes with malign intent.

According to NIST officials, OSTP's delays in issuing the forms and guidelines have delayed NIST's collection of certain disclosures. Without these disclosures, NIST is missing key information—such as domestic researchers' participation in foreign talent recruitment programs—that could help it address research security risks.

Separately, NIST requires fewer disclosures from domestic associates than from foreign national associates. Officials said the agency primarily focuses on risks posed by foreign national associates and by certain countries of concern. However, domestic researchers can also have concerning affiliations with foreign entities. By not requiring domestic associates to disclose the same information as foreign national associates, NIST is missing opportunities to assess and mitigate risks.

Information That NIST Requires Associates to Disclose

Source: GAO analysis of the National Institute of Standards and Technology (NIST) information. | GAO-24-106074

NIST and Commerce also help ensure research security by training researchers. The training program generally aligns with most selected leading training practices. However, because they do not evaluate the program's effectiveness, the agencies are limited in their ability to identify opportunities for improvement. For example, NIST employees told GAO that NIST could provide more examples of risks that employees may encounter. Collecting and analyzing such feedback could help strengthen the agency's training and improve research security.

Why GAO Did This Study

Countries of concern pose security risks to U.S. research and innovation. Such countries have sought to access information through collaborative research efforts. NIST employees regularly collaborate with outside researchers from academia or private-sector companies. The Research and Development, Competition, and Innovation Act includes a provision for GAO to review NIST's research security program.

This report examines, among other things, NIST's efforts to (1) meet federal disclosure requirements for intramural and extramural researchers, (2) collect and review disclosures from foreign national associates and domestic associates, and (3) align its security training with selected leading training practices.

GAO reviewed NIST's information and available data on identified risks, research security policies, and procedures, and interviewed agency officials. GAO also compared NIST's policies and practices against selected federal requirements and leading practices on training.

Recommendations

GAO is making three recommendations: one to OSTP on issuing timely research security guidance; and two to NIST on strengthening disclosure requirements for domestic associates and evaluating its training program. OSTP and NIST agreed with the recommendations.

Recommendations for Executive Action

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What Is a Disclosure? Definition in Business and How They Work

What is a disclosure explained in plain english.

Disclosure is the process of making facts or information known to the public. Proper disclosure by corporations is the act of making its customers, investors, and any people involved in doing business with the company aware of pertinent information.

Disclosures are at the center of the public's crisis of confidence when it comes to the corporate world. They should be viewed as a very important and informative part of doing business with or investing in a company. This article will define disclosure and show why it's important as it relates to companies and investors.

Key Takeaways

  • Disclosure is the process of making facts or information known to the public.
  • Proper disclosure by corporations is the act of making its customers, investors, and analysts aware of pertinent information.
  • Companies often place disclosures that protect them in case their financial forecasts are wrong due to changing economic conditions.
  • Corporate disclosures also state that investors speak with a financial advisor before investing in the stock since it might not be right for them.

How Disclosures Work

In the investing world, corporations issue disclosures to provide investors and investment analysts with information that could influence an investor's decision whether to buy a company's stock or bonds . The disclosure statement can reveal negative or positive news and financial information about the company.

Investment research reports also disclose the nature of the relationship between the equity analysts, their employer, such as the investment firm, and the company that is the subject of the research report–called the subject company . It also provides critical facts that investors should be aware of, such as warning-like statements.

The Securities and Exchange Commission (SEC) requires that all research reports contain a disclosure statement.   If you are reading a research report that does not have a disclosure statement, you should disregard it, as it can not be trusted.

Why Disclosures Are Important

The disclosure is as important to a research report as footnotes are to a corporate financial report. Footnotes are used by corporations to provide investors with details of specific financial line items within the company's financial statements .

Disclosures appear at the end of a research report and usually in very small print, like footnotes to a 10-K , which is a company's annual financial report. It may take a magnifying glass and a strong cup of coffee, but when reading a disclosure, investors should be able to determine who "paid" for the research report and the degree of objectivity that may, or may not, be present.

Disclosures that are written clearly and succinctly help investors to better trust the data and findings being shared in a research report.

Disclosures in Plain English

Unfortunately, disclosure statements are quite often written by lawyers who are more concerned with protecting the brokerage firm than providing easy-to-read information for investors. Lawyers use legal boilerplate clauses that make disclosures verbose and hard to read—hence the need for the strong coffee. Disclosures are often published in small type because they tend to be lengthy.

Below are some of the key points covered, or stated, in most disclaimers:

"This report contains forward-looking statements... actual results may differ from our forecasts."

In plain English, "This is our best guess, but we may be wrong." Companies and investment analysts often forecast revenue , sales, and business development. However, things can change, such as economic conditions could deteriorate. Anytime a company or analyst makes an oral or written statement about the company's future financial performance, it'll typically include a forward-looking statement disclosure.

"This report is based on information from resources that we believe to be correct, but we haven't checked it."

In other words, we may assume that corporate financial statements contain true information about a company's operations, but no analyst can audit a company's books to verify the truth of that assumption. That is the job of the accountants .

"This report is being provided for informational purposes only, and on the condition that it will not form a primary basis for any investment decision."

Equity analysts can't provide investment advice suggesting that investors buy a company's stock. Companies will also use this disclosure. Both analysts and company executives don't know the specific financial situation of investors, such as whether they're a retiree or a millennial.

A retiree, for example, might be better off investing bonds or safe investments. There are many factors that go into an investment decision of whether to buy a stock besides the financial performance of the company. Economic conditions , the investor's risk tolerance , and asset allocation can all impact the decision.

As a result, companies and investment firms often put this disclosure to protect them from appearing that they're suggesting that an investor buy the stock solely on the information in the report.

"Investors should make their own determination of whether or not to buy or sell this stock-based upon their specific investment goals, and in consultation with their financial advisor."

This disclosure is very similar to the previous one and probably is the best bit of advice for a disclaimer. In other words, investors should consider all possible scenarios, including their financial situation and seek the help of a financial adviser in determining whether this stock is good for them.

Nature of Relationship

Investors should look for any conflicts of interest in the disclosure statements by looking for answers to these questions.

  • What is the nature of the relationship between the subject company and the brokerage firm?
  • Does the firm make a market in the stock and have they done investment banking for the subject company?

Brokerage firms do not produce research reports for free. Historically, income generated from trading, or investment banking, has funded research departments.

  • Do the analysts and other members of the firm trade or own shares in the subject company? 

It's not necessarily bad that an analyst owns a security that is being touted by the investment firm. However, it's important to disclose this information since stock ownership could impact the analyst's opinion of whether someone should buy the stock.

U.S. Securities and Exchange Commission. " Report on Review of Disclosure Requirements in Regulation S-K ," Page 8.

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Last updated: March 9, 2022

NIH requires the disclosure of biographical, other support and foreign component information as part of the grant application process and, as requested, in post-award progress reports. The information below summarizes key NIH disclosure requirements and provides links to more detailed information.

Effective January 25, 2022:

  • Supporting documentation for outside contracts, agreements and other working arrangements with foreign entities must be submitted with Other Support . See “Supporting Documentation” in the Other Support section below for instructions on how to comply with these requirements at MIT.
  • The new FORMS-G for Other Support has an added signature block for the PI/KP to certify the accuracy of the information submitted. Each form must be electronically signed by the PI/KP and submitted as a flattened PDF. Electronic signatures can be generated using DocuSign or Adobe Pro DC (requires external license); wet signatures and image files are not acceptable . RA Support has prepared instructions for preparing and flattening PDF attachments .

Biographical Sketch

What to Disclose

The biographical sketch (biosketch) provides an opportunity for each senior/key person listed in an NIH grant application to describe why they are well-suited for their role(s) in the project. All senior/key personnel are required to provide biosketches. Senior/Key personnel includes Investigators, Other Significant Contributors (OSC), plus could include consultants and technical staff if they meet the definition of senior/key personnel. Senior/Key personnel do not necessarily need to be paid from the grant, but they do require effort. The only exception is the role of OSC, they do not need to commit effort by definition of that particular role. OSCs should also certify in the MIT Kuali Coeus (KC) system. Required information in the biosketch may vary depending on the solicitation type, so please review the solicitation details.

When to Disclose

Biographical sketches (biosketches) are required in new and competing grant applications.

See NIH Biosketch Format Pages, Instructions and Samples for details .

Other Support

“Other Support” is sometimes referred to as “current and pending support” or “active and pending support”.  Information on other support may be requested (often as part of Just-in-Time procedures for grant applications or in progress reports) to ensure there is no scientific, budgetary, or commitment overlap. The following information is excerpted and adapted from the  NIH Other Support website  and  NOT-OD-19-114: Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components . Please refer to these resources,  NIH FAQs on Other Support , or contact your  RAS administrator  if you have questions.

Other support includes all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant. This includes resource and/or financial support from all foreign and domestic entities, including but not limited to, financial support for laboratory personnel, and provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.).

NIH applicants must:

  • List all positions and scientific appointments both domestic and foreign held by senior/key personnel that are relevant to an application including affiliations with foreign entities or governments. This includes titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
  • Report all resources and other support for all individuals designated in an application as senior/key personnel – including for the program director/principal investigator (PD/PI) and for other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they request salaries or compensation. Information must be provided about all current support for ongoing projects, irrespective of whether such support is provided through the applicant organization, through another domestic or foreign organization, or is provided directly to an individual that supports the senior/key personnel’s research efforts.
  • Report all current projects and activities that involve senior/key personnel, even if the support received is only in-kind (e.g. office/laboratory space, equipment, supplies, employees). All research resources including, but not limited to, foreign financial support, research or laboratory personnel, lab space, scientific materials, selection to a foreign “talents” or similar-type program, or other foreign or domestic support must be reported.
  • Provide the total award amount for the entire award period covered (including facilities and administrative costs), as well as the number of person-months (or partial person-months) per year to be devoted to the project by the senior/key personnel involved.

All pending support at the time of application submission and prior to award must be reported using  “Just-in-Time Procedures”  by providing all information indicated above. Applicants are responsible for promptly notifying NIH of any substantive changes to previously submitted Just-in-Time information up to the time of award, including “Other Support” changes that must be assessed for budgetary or scientific overlap.

Further, if other support, as described as above, is obtained after the initial NIH award period, from any source either through the institution or directly to senior/key personnel, the details must be disclosed in the annual research performance progress report (RPPR). Post-award, recipients must address any substantive changes by submitting a prior approval request to NIH in accordance with the NIHGPS section on “Administrative Requirements—Changes in Project and Budget—NIH Standard Terms of Award.”

Supporting Documentation (effective January 25, 2022)

MIT has developed the External Contract Depository (ECD) to help MIT researchers and their administrators meet the newly-enacted National Institutes of Health (NIH) requirement that principal investigators and senior/key personnel provide copies of outside contracts, or other agreements, with foreign entities as part of their Other Support submission. Uploaded documents will receive a high-level review by MIT’s Office of the Vice President for Research and the Office of the General Counsel to help ensure compliance with NIH requirements. In order to maintain consistency of reporting, only contracts that have been uploaded to this depository and reviewed should be included in submissions to NIH.

Foreign Components

NIH requires recipients to determine whether activities it supports include a foreign component, defined as "the existence of any 'significant scientific element or segment of a project'…" outside of the United States. This includes:

  • Performance of work by a researcher or recipient in a foreign location, whether or not NIH grant funds are expended and/or
  • Performance of work by a researcher in a foreign location employed or paid for by a foreign organization, whether or not NIH grant funds are expended.

If a recipient determines that a portion of the project will be conducted outside of the U.S., the recipient then will need to determine if the activities are considered significant. If both criteria are met, then there is a foreign component that must be disclosed in Item 6 of the  Research & Related Other Project Information Form . See item B2 in the  NIH FAQS  for further guidance how about to determine if activities are significant.

The addition of a foreign component to an ongoing NIH grant continues to require NIH prior approval, as outlined in the NIH Grants Policy Statement,  Section 8.1.2 , Prior Approval Requirements.

Foreign components are reported in Section G.9 of the NIH  Research Performance Progress Report (RPPR) . For additional information, see page 99 of the  RPPR Instructional Guide .

Note: If an activity does not meet the definition of foreign component because all research is being conducted within the United States, but there is a non-U.S. resource that supports the research of an investigator and/or researcher, it must be reported as other support. For example, if a PD/PI of an NIH-funded grant has a collaborator outside of the U.S. who performs experiments in support of the PD/PI’s NIH-funded project, this would constitute a foreign component, regardless of whether the foreign collaborator receives funding from the PD/PI’s grant. Additional funding from a foreign source for the NIH-supported research of a PD/PI at a U.S. institution would not constitute a foreign component but would necessitate reporting as other support.

The following links to the NIH Blog also describe the purpose and obligation to disclose properly and fully:

  • Addressing Foreign Interference and Associated Risks to the Integrity of Biomedical Research, and How You Can Help
  • Clarifying Long-Standing NIH Policies on Disclosing of Other Support

See the MIT Office of the Vice President for Research Foreign Engagement  page for recent updates and additional resources regarding foreign engagements.

Portions of the contents of this page were adapted from materials prepared by UCLA Research Policy and Compliance and are provided here with their permission.

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Research Security and the Cost of Compliance – Phase I Report, Disclosure Requirements Now Available

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COGR conducted Phase I of the survey described in this report to quantify the considerable time and resources (financial and otherwise) that research institutions have invested (or will invest) to achieve compliance with the Disclosure Requirements.  COGR is providing this Phase I report to research institutions and federal research funding agencies in the hope that it will both encourage and facilitate discussions of equitable cost allocation, as well as how “return on investment” (ROI) should be considered and measured.

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Fact Sheet 42 CFR Part 2 Final Rule 

Date: February 8, 2024

On February 8, 2024, the U.S. Department of Health & Human Services (HHS) through the Substance Abuse and Mental Health Services Administration (SAMHSA) and the Office for Civil Rights announced a final rule modifying the Confidentiality of Substance Use Disorder (SUD) Patient Records regulations at 42 CFR part 2 (“Part 2”). With this final rule, HHS is implementing the confidentiality provisions of section 3221 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act (enacted March 27, 2020), which require the Department to align certain aspects of Part 2 with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Rules and the Health Information Technology for Economic and Clinical Health Act (HITECH).

The Part 2 statute (42 U.S.C. 290dd-2) protects “[r]ecords of the identity, diagnosis, prognosis, or treatment of any patient which are maintained in connection with the performance of any program or activity relating to substance use disorder education, prevention, training, treatment, rehabilitation, or research, which is conducted, regulated, or directly or indirectly assisted by any department or agency of the United States.” Confidentiality protections help address concerns that discrimination and fear of prosecution deter people from entering treatment for SUD.

The modifications in this final rule reflect the proposals published in the December 2, 2022, Notice of Proposed Rulemaking (NPRM) and public comments received from: substance use disorder and other advocacy groups; trade and professional associations; behavioral and other health providers; health information technology vendors and health information exchanges; state, local, tribal and territorial governments; health plans; academic institutions, including academic health centers; and unaffiliated or anonymous individuals. Following a 60-day comment period, HHS analyzed and carefully considered all comments submitted from the public on the NPRM and made appropriate modifications before finalizing.

Major Changes in the New Part 2 Rule

The final rule includes the following modifications to Part 2 that were proposed in the NPRM:

  • Allows a single consent for all future uses and disclosures for treatment, payment, and health care operations.
  • Allows HIPAA covered entities and business associates that receive records under this consent to redisclose the records in accordance with the HIPAA regulations. 1
  • Permits disclosure of records without patient consent to public health authorities, provided that the records disclosed are de-identified according to the standards established in the HIPAA Privacy Rule.
  • Restricts the use of records and testimony in civil, criminal, administrative, and legislative proceedings against patients, absent patient consent or a court order.
  • Penalties : Aligns Part 2 penalties with HIPAA by replacing criminal penalties currently in Part 2 with civil and criminal enforcement authorities that also apply to HIPAA violations. 2
  • Breach Notification : Applies the same requirements of the HIPAA Breach Notification Rule 3 to breaches of records under Part 2.
  • Patient Notice : Aligns Part 2 Patient Notice requirements with the requirements of the HIPAA Notice of Privacy Practices.
  • Safe Harbor : Creates a limit on civil or criminal liability for investigative agencies that act with reasonable diligence to determine whether a provider is subject to Part 2 before making a demand for records in the course of an investigation. The safe harbor requires investigative agencies to take certain steps in the event they discover they received Part 2 records without having first obtained the requisite court order.

Substantive Changes Made Since the NPRM

In addition to finalizing modifications to Part 2 that were proposed in the NPRM, the Final Rule includes further modifications informed by public comments, notably the following:

  • Safe Harbor: Clarifies and strengthens the reasonable diligence steps that investigative agencies must follow to be eligible for the safe harbor: before requesting records, an investigative agency must look for a provider in SAMHSA’s online treatment facility locator and check a provider’s Patient Notice or HIPAA Notice of Privacy Practices to determine whether the provider is subject to Part 2.
  • Segregation of Part 2 Data : Adds an express statement that segregating or segmenting Part 2 records is not required.
  • Complaints : Adds a right to file a complaint directly with the Secretary for an alleged violation of Part 2. Patients may also concurrently file a complaint with the Part 2 program.
  • SUD Counseling Notes : Creates a new definition for an SUD clinician’s notes analyzing the conversation in an SUD counseling session that the clinician voluntarily maintains separately from the rest of the patient’s SUD treatment and medical record and that require specific consent from an individual and cannot be used or disclosed based on a broad TPO consent. This is analogous to protections in HIPAA for psychotherapy notes. 4
  • Prohibits combining patient consent for the use and disclosure of records for civil, criminal, administrative, or legislative proceedings with patient consent for any other use or disclosure.
  • Requires a separate patient consent for the use and disclosure of SUD counseling notes.
  • Requires that each disclosure made with patient consent include a copy of the consent or a clear explanation of the scope of the consent.
  • Fundraising : Create a new right for patients to opt out of receiving fundraising communications.

What has not changed in Part 2?

As has always been the case under Part 2, patients’ SUD treatment records cannot be used to investigate or prosecute the patient without written patient consent or a court order.

Records obtained in an audit or evaluation of a Part 2 program cannot be used to investigate or prosecute patients, absent written consent of the patients or a court order that meets Part 2 requirements.

What comes next?

The final rule may be downloaded at https://www.federalregister.gov/public-inspection/2024-02544/confidentiality-of-substance-use-disorder-patient-records . HHS will support implementation and enforcement of this new rule, including through resources related to behavioral health developed by the SAMHSA-sponsored Center of Excellence for Protected Health Information . Persons subject to this regulation must comply with the applicable requirements of this final rule two years after the date of its publication in the Federal Register . The Department will conduct outreach and develop guidance on how to comply with the new requirements, such as filing breach reports when required.

OCR plans to finalize changes to the HIPAA Notice of Privacy Practices (NPP) to address uses and disclosures of protected health information that is also protected by Part 2 along with other changes to the NPP requirements, in an upcoming final rule modifying the HIPAA Privacy Rule.

HHS planning to implement in separate rulemaking the CARES Act antidiscrimination provisions that prohibit the use of patients’ Part 2 records against them.

1   However, these records cannot be used in legal proceedings against the patient without specific consent or a court order, which is more stringent than the HIPAA standard.

2    See 42 U.S.C. 1320d–5 and 1320d-6.

3   Section 13400 of the HITECH Act (codified at 42 U.S.C. 17921) defined the term “Breach”. Section 13402 of the HITECH Act (codified at 42 U.S.C. 17932) enacted breach notification requirements, discussed in detail below.

4    See https://www.hhs.gov/hipaa/for-professionals/faq/2088/does-hipaa-provide-extra-protections-mental-health-information-compared-other-health.html .

research report disclosure requirements

Fact Sheet: Anti-Money Laundering Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers Notice of Proposed Rulemaking (NPRM)

The U.S. investment adviser industry provides an important service to investors in the United States and across the world in driving investment opportunities and supporting innovation, growth, and prosperity in the United States. But investment advisers, in their role as gatekeepers to the U.S. financial system, are at risk of abuse by money launderers, corrupt officials, and other bad actors. Thousands of investment advisers overseeing the investment of tens of trillions of dollars into the U.S. economy are generally not subject to comprehensive anti-money laundering and countering the financing of terrorism (AML/CFT) measures.

The proposed rule would require certain investment advisers to apply AML/CFT requirements pursuant to the Bank Secrecy Act (BSA), including implementing risk-based AML/CFT programs, reporting suspicious activity to FinCEN, and fulfilling recordkeeping requirements.

Building on the 2021 U.S. Strategy on Countering Corruption , Treasury conducted a risk assessment  of the investment advisers sector that identified several illicit finance and national security risks. The risk assessment found several cases in which sanctioned individuals, corrupt officials, tax evaders, and other criminal actors have used investment advisers as an entry point to invest in U.S. securities, real estate, and other assets. Treasury’s risk assessment also identified cases of foreign adversaries, including China and Russia, investing in early-stage companies through investment advisers to access sensitive information and emerging technology.

While certain investment advisers may be subject to AML/CFT requirements, or perform some AML/CFT requirements voluntarily or via contract, Treasury’s risk assessment found that the lack of comprehensive AML/CFT requirements across the sector contributed to its vulnerability to illicit finance activity. Further, Treasury has found that the investment adviser sector has nearly doubled in assets under management (AUM) since Treasury’s issuance of a prior NPRM in 2015 proposing to apply AML/CFT measures to certain investment advisers. The size and rapid growth of this sector underscore the importance of recalibrating the regulatory environment.

FinCEN has issued an NPRM (hyperlink) detailing a proposed rule that would apply comprehensive AML/CFT measures to certain investment advisers. The NPRM will give the public the opportunity to review and comment on the proposed rule. FinCEN is also withdrawing the 2015 NPRM.

Investment Advisers

Investment advisers are entities that provide advice to investors about securities for compensation as part of a regular business. Investment advisers provide their expertise to a wide range of clients, including retail investors, high-net-worth individuals, private institutions, and governmental entities (including local, state, and foreign government funds). Advisers typically provide ongoing advice about buying, selling and/or holding investments and will monitor the performance of clients’ investments and their alignment with clients’ overall investment objectives. Many clients grant the adviser the power to manage assets on a discretionary basis, meaning the adviser has the authority to decide which securities to purchase and sell for the client.

Investment Advisers Covered by the Proposed Rule

The proposed rule would include certain investment advisers in the definition of “financial institution” under the BSA:

  • investment advisers registered with the Securities and Exchange Commission (SEC), also known as registered investment advisers (RIAs), and
  • investment advisers that report to the SEC as exempt reporting advisers (ERAs).

Investment advisers generally must register with the SEC if they have over $110 million in AUM. ERAs are investment advisers that (1) advise only private funds and have less than $150 million in AUM in the United States or (2) advise only venture capital funds. ERAs are exempt from SEC registration but still must file certain information with the SEC.

Requirements of the Proposed Rule

The proposed rule would require RIAs and ERAs to:

  • implement an AML/CFT program;
  • file certain reports, such as Suspicious Activity Reports (SARs), with FinCEN;
  • keep records such as those relating to the transmittal of funds (i.e., comply with the Recordkeeping and Travel Rule); and
  • fulfill other obligations applicable to financial institutions subject to the BSA and FinCEN’s implementing regulations.

The proposed rule would also apply information-sharing provisions between and among FinCEN, law enforcement government agencies, and certain financial institutions to investment advisers, along with subjecting investment advisers to the “special measures” imposed by FinCEN pursuant to Section 311 of the USA PATRIOT Act.

At this time, FinCEN is not proposing a customer identification program requirement for investment advisers. FinCEN anticipates addressing customer identification program requirements for investment advisers in a future joint rulemaking with the SEC. FinCEN is also not proposing an obligation for investment advisers to collect beneficial ownership information for legal entity customers. FinCEN anticipates addressing this requirement for investment advisers in a subsequent rulemaking.

FinCEN has tailored the requirements of the proposed rule to minimize potential business burden as much as possible while still pursuing transparency initiatives to safeguard our financial system and protect American innovation. FinCEN has been careful not to pile on additional or redundant requirements for investment advisers. Because investment advisers provide services to open-end investment companies such as mutual funds, which are already defined as “financial institutions” under the BSA, and because of the regulatory and practical relationship between mutual funds and their investment advisers, the proposed rule would not require investment advisers to apply AML/CFT program or SAR filing requirements to mutual funds they advise.

Finally, FinCEN is proposing to delegate its examination authority to the SEC, the federal functional regulator responsible for the oversight and regulation of investment advisers. The proposed delegation would be consistent with FinCEN’s existing delegation to the SEC of the authority to examine brokers and dealers in securities and mutual funds for compliance with the BSA and FinCEN’s implementing regulations.

Benefits of the Proposed Rule

The proposed rule would significantly improve efforts to protect the U.S. financial system, provide highly useful information to law enforcement authorities and national security agencies, and safeguard the investment adviser sector against illicit activity. Furthermore, the proposed rule would make it easier for U.S. investment advisers and the U.S. government to identify attempts by foreign adversaries to invest in early-stage companies with ties to important and sensitive technologies with national security implications.

The proposed rule would also bring the U.S. in line with international counterparts and address a deficiency identified by the Financial Action Task Force (FATF) in its 2016 Mutual Evaluation of the United States.

The proposed rule is designed to improve outcomes for U.S. investors and to help safeguard investments in the United States. It would improve the detection and reporting of suspicious activity to assist regulators and law enforcement in combating illicit finance, including fraud, in the investment adviser industry. The proposed rule would also help level the regulatory playing field and mitigate illicit finance risks arising from potential regulatory arbitrage by illicit actors who might choose between investment advisers applying varying AML/CFT measures.

Under the proposed rule, covered investment advisers would be required to comply with the rule on or before 12 months from the final rule’s effective date.

The comment period for the NPRM is open until April 15, 2024.

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Agencies launch SECURE 2.0 reporting and disclosure review 

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Margaret Berger

Focus on effectiveness

Scope of report to congress, questions for stakeholders, participant disclosures.

The agencies say that a disclosure’s effectiveness can be evaluated from the perspective of both the participants receiving the information and the plans providing it. To that end, the RFI asks questions to gauge how participants receive and comprehend required notices, along with questions on how to improve the process of furnishing these disclosures.

  • Receipt and comprehension . The RFI asks how different factors affect participants’ comprehension of disclosures and where opportunities for improvement might exist. The agencies specifically ask for assessments of how the effectiveness of disclosures correlates with their number and timing; their content, length, and complexity; and their readability for native and nonnative English speakers. The agencies also want information about when and how participants access and retain disclosures, and what (if any) steps plans take in response to participants’ lack of engagement.
  • Furnishing required disclosures. The agencies want to understand the perspective of plans, plan administrators, and service providers responsible for preparing and delivering participant disclosures. The RFI includes questions on how plans obtain participants’ contact information and use electronic delivery methods to furnish disclosures (including any observable trends in participants’ receipt and opt-out rates). The agencies are interested in comments on how much providing disclosures cost, whether model agency notices reduce those costs and whether additional models would be helpful (including in languages other than English). The RFI also asks for suggestions on how to reduce these costs without diminishing the disclosures’ effectiveness.

Reporting to the agencies

Commenters are asked to give their insights into the reporting process and the usefulness of the reported information. Regulators are considering not only plans’ perspectives but also those of the agencies receiving the reports, participants and beneficiaries of reporting plans, and third parties that may rely on reported information for study or participant advocacy.

  • Submission of reports . The RFI asks for comments on the frequency, timing and content of required reports. The agencies question whether instructions should be subject to a readability standard (similar to the one that applies to participant disclosures), whether filing methods are efficient and whether filers receive adequate customer service support. The RFI also looks for information on how much reporting costs and whether some reports are more expensive than others.
  • Use of publicly available information. The agencies want to know if any of the information already provided to them might also be useful for participants and, if so, could be provided to them in a cost-effective manner. The RFI also includes questions on the reports’ usefulness for other entities like the public, data aggregators and participant advocates, including how to manage confidentiality and security concerns relating to public release of the information.

Agencies limit RFI’s coverage of reporting requirements

Although the RFI is expansive, it excludes certain reporting requirements.

  • Form 5500 series omitted. The agencies urge commenters to focus on information and analyses beyond the Form 5500 annual reporting series . While acknowledging that Form 5500 is a key component of retirement plan reporting, the agencies believe they already have a sufficient process for soliciting feedback as part of their annual review of the form. (When finalizing SECURE 2.0-related reporting changes last year, DOL indicated that the agencies expect to propose a broader Form 5500 modernization project in the near future to make investment and other information more data-mineable.)
  • Enforcement activity and other exclusions. Information provided in the context of an audit, examination, investigation or enforcement action is outside the RFI’s scope, as is information that plan officials voluntarily furnish to obtain favorable treatment (for instance, as part of a submission under IRS’s Employee Plans Compliance Resolution System or DOL’s Voluntary Fiduciary Correction Program). The RFI also excludes any submission to the agencies that isn’t specific to retirement plans, such as reporting on foreign investment holdings.

Additional questions

Reliance on other information sources, related resources, non-mercer resources.

  • RFI on SECURE 2.0 Section 319 (Federal Register, Jan. 23, 2024)
  • Div. T of Pub. L. No. 117-328 , the SECURE 2.0 Act of 2022 (Congress, Dec. 29, 2022)

Mercer Law & Policy resources

  • User's guide to SECURE 2.0 (updated regularly)
  • DOL starts tackling SECURE 2.0 reporting and disclosure updates (Sept. 19, 2023)
  • Form 5500 trilogy concludes with latest set of changes (March 13, 2023)
  • DOL proposes new electronic delivery rule for retirement plan notices (Nov. 1, 2019)

EU AI Act: first regulation on artificial intelligence

The use of artificial intelligence in the EU will be regulated by the AI Act, the world’s first comprehensive AI law. Find out how it will protect you.

A man faces a computer generated figure with programming language in the background

As part of its digital strategy , the EU wants to regulate artificial intelligence (AI) to ensure better conditions for the development and use of this innovative technology. AI can create many benefits , such as better healthcare; safer and cleaner transport; more efficient manufacturing; and cheaper and more sustainable energy.

In April 2021, the European Commission proposed the first EU regulatory framework for AI. It says that AI systems that can be used in different applications are analysed and classified according to the risk they pose to users. The different risk levels will mean more or less regulation. Once approved, these will be the world’s first rules on AI.

Learn more about what artificial intelligence is and how it is used

What Parliament wants in AI legislation

Parliament’s priority is to make sure that AI systems used in the EU are safe, transparent, traceable, non-discriminatory and environmentally friendly. AI systems should be overseen by people, rather than by automation, to prevent harmful outcomes.

Parliament also wants to establish a technology-neutral, uniform definition for AI that could be applied to future AI systems.

Learn more about Parliament’s work on AI and its vision for AI’s future

AI Act: different rules for different risk levels

The new rules establish obligations for providers and users depending on the level of risk from artificial intelligence. While many AI systems pose minimal risk, they need to be assessed.

Unacceptable risk

Unacceptable risk AI systems are systems considered a threat to people and will be banned. They include:

  • Cognitive behavioural manipulation of people or specific vulnerable groups: for example voice-activated toys that encourage dangerous behaviour in children
  • Social scoring: classifying people based on behaviour, socio-economic status or personal characteristics
  • Biometric identification and categorisation of people
  • Real-time and remote biometric identification systems, such as facial recognition

Some exceptions may be allowed for law enforcement purposes. “Real-time” remote biometric identification systems will be allowed in a limited number of serious cases, while “post” remote biometric identification systems, where identification occurs after a significant delay, will be allowed to prosecute serious crimes and only after court approval.

AI systems that negatively affect safety or fundamental rights will be considered high risk and will be divided into two categories:

1) AI systems that are used in products falling under the EU’s product safety legislation . This includes toys, aviation, cars, medical devices and lifts.

2) AI systems falling into specific areas that will have to be registered in an EU database:

  • Management and operation of critical infrastructure
  • Education and vocational training
  • Employment, worker management and access to self-employment
  • Access to and enjoyment of essential private services and public services and benefits
  • Law enforcement
  • Migration, asylum and border control management
  • Assistance in legal interpretation and application of the law.

All high-risk AI systems will be assessed before being put on the market and also throughout their lifecycle.

General purpose and generative AI

Generative AI, like ChatGPT, would have to comply with transparency requirements:

  • Disclosing that the content was generated by AI
  • Designing the model to prevent it from generating illegal content
  • Publishing summaries of copyrighted data used for training

High-impact general-purpose AI models that might pose systemic risk, such as the more advanced AI model GPT-4, would have to undergo thorough evaluations and any serious incidents would have to be reported to the European Commission.

Limited risk

Limited risk AI systems should comply with minimal transparency requirements that would allow users to make informed decisions. After interacting with the applications, the user can then decide whether they want to continue using it. Users should be made aware when they are interacting with AI. This includes AI systems that generate or manipulate image, audio or video content, for example deepfakes.

On December 9 2023, Parliament reached a provisional agreement with the Council on the AI act . The agreed text will now have to be formally adopted by both Parliament and Council to become EU law. Before all MEPs have their say on the agreement, Parliament’s internal market and civil liberties committees will vote on it.

More on the EU’s digital measures

  • Cryptocurrency dangers and the benefits of EU legislation
  • Fighting cybercrime: new EU cybersecurity laws explained
  • Boosting data sharing in the EU: what are the benefits?
  • EU Digital Markets Act and Digital Services Act
  • Five ways the European Parliament wants to protect online gamers
  • Artificial Intelligence Act

Related articles

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