The “Boulder Letter” explained why opting into a state statute limiting a shareholder’s ability to vote all their shares violates the Investment Company Act. SEC Staff recently repealed the Letter. Consistent with other recent actions, this dilutes the rights of shareholders. In conclusion, another democratic-free zone was provided to entrenched managers and boards. If you […]
SEC Rulemaking Comment Tips: Action Needed SEC rulemaking comment tips repeated here are primarily based on advice from the Council of Institutional Investors. However, I am also including tips from the Sustainable, Responsible and Impact Investing, conference I attended in Colorado Springs in November. (Search #SRI30 for other Conference tidbits at CorpGov.net and on Twitter.) […]
Take Action: Comment on SEC’s Rule 14a-8(i)(9) Review As proxy season draws to an end, managers, boards and their legal advisors are calling on the SEC to allow companies to exclude shareholder proposals if a company includes a proxy proposal on the same subject, even if it would do the opposite of the shareholder proposal. […]
The Securities and Exchange Commission (SEC) announced that Brent J. Fields has been appointed as the agency’s Secretary, who is responsible for overseeing the administrative aspects of Commission meetings, rulemakings, and procedures. Let’s give Mr. Fields a warm welcome with a flood of e-mail supporting the petition to require companies to disclose political spending. (more…)
Worth Reading … SEC Comment Letters on Proxy Plumbing | Governance Center Blog. Gary Larkin, writing for the Conference Board, points to several comment letters worth reading. I’m pleased to have my letter among those listed. I’ve greatly abbreviated Larkin’s list and added a few nominees. The Corporate Governance Network, James McRitchie, Publisher, Oct. 20. […]
On July 14, 2010 the Securities and Exchange Commission voted unanimously to issue a concept release seeking public comment on the U.S. proxy system and asking whether rule revisions should be considered to promote greater efficiency and transparency. Today is the last day to comment within the formal timeline. Looking through the comments posted thus […]
As many of you know, I petitioned the SEC last year to change the rule that allows blanks on a partially filled proxy or voter instruction forms (VIFs) to go to management and have also complained to the SEC about Broadridge’s failure to impartially identify proxy proposals on VIFs (see Investors Against Genocide Fighting American […]
With an agenda full of mandated studies and rulemaking related to the Dodd-Frank Act, the SEC is trying a new approach to obtaining public input: Inviting public comment on a number of topics even before they get started through a number of e-mail boxes. Staff will also “try to meet with any interested parties who […]