Extension-Sought-on-SEC-Rulemaking-Comment-Period

Extension Sought on SEC Comment Period

Extension sought by Josh Zinner of ICCR for SEC comment period on potentially explosive rulemakings of critical importance to all shareholders. Shareholders would do well to follow his lead by joining him in requesting a 120 day comment period for these complex rules.

Extension Sought by ICCR to Extend Comment Period

S7-23-19: Procedural Requirements and Resubmission Thresholds under Exchange Act Rule 14a-8. Comments posted. Submit comments.

S7-22-19: Amendments to Exemptions from the Proxy Rules for Proxy Voting Advice. Comments posted. Submit comments.

Dear Chairman Clayton,

I write to request an extension of the comment period regarding 1) Procedural Requirements and Resubmission Thresholds under Exchange Act Rule 14a-8 and 2) S7-22-19: Amendments to Exemptions from the Proxy Rules for Proxy Voting Advice from 60 days to 120 days.

Given the complexity of the combined 320 pages of proposed changes, and the potential magnitude of such changes to an effective process that has been in place for decades, the 60 day comment period is far too short. This short window is particularly difficult given the coming holiday season. For these reasons, we respectfully request an extension of the comment period to 120 days.

Sincerely,

Josh Zinner
CEO
Interfaith Center on Corporate Responsibility

Update: CII also requested a 120 day comment period and many have co-filed with them.

   

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One Response to Extension Sought on SEC Comment Period

  1. James McRitchie November 18, 2019 at 6:05 am #

    I submitted the following statement on both proposals:

    This is to request the comment period the the rulemaking be extended to 180 days, which is the standard for complex proposals. The proposal explicitly and repeatedly request that commentators provide supporting data. To the extent possible, I intend to be responsive to this request in comment letters.

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