August 17, 2020 Assistant Secretary Preston Rutledge EBSA Department of Labor200 Constitution Ave, NW, Ste S-2524 Washington DC 20210 RE: RIN 1210-AB95 NPRM: Financial Factors in Selecting Plan Investment Dear Assistant Secretary Rutledge, This is a supplement to our earlier comment to reflect recent developments and respond to a claim made in one comment. While we disagree…
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Church group criticises US plan to rein in smaller shareholders | Business | The Guardian
Managers of the Church of England’s £8.3bn investment portfolio have criticised US regulators for planning to deny smaller shareholders, such as the church, the right to challenge US companies over excessive executive pay and the climate crisis. A group of 70 church investors, including the C of E, have written to the US Securities and…
VEA Comment on the SEC’s Awful Proxy Advisory Proposal
The full text of our comment is below. An excerpt: I agree with the Commission’s own advisory committee and the letters on behalf of investors filed by CII, T. Rowe Price, John Coates and Barbara Roper, and others that this proposal is wrongly conceived. Despite the Commission’s rhetoric of support for proxy voting, this proposed…
Coates-Roper Comment on SEC Proposal
Two members of the IAC subcommittee have filed supplemental comments, Harvard Law Professor John Coates and Consumer Federation of America’s Barbara Roper. The full comment is below. An excerpt: The SEC’s proposal on proxy advisors treats them as the most important actors in the proxy system outside of corporate managers. In fact, the largest fund…
T. Rowe Price Comment on Proxy Advisory Proposal
T. Rowe Price has filed one of the best comments we’ve seen on the SEC’s proposed rule on proxy advisory firms. The full comment is below. An excerpt: We join others in noting that the Proposal appears to be a solution in search of a problem. Its stated objective is to improve the accuracy, transparency…
Comment to the SEC: Investor-as-Owner Subcommittee of the SEC Investor Advisory Committee (IAC) Relating to SEC Guidance and Rule Proposals on Proxy Advisors and Shareholder Proposals
The SEC’s own Investor-as-Owner Subcommittee of the SEC Investor Advisory Committee does not approve of the proposed rule on proxy advisory firms and proxy proposals. An excerpt: The IAC has long urged the Commission to address a variety of problems in the proxy system, and there are valuable elements in the PA/SP actions, such as…
Fact and Fantasy in SEC Rules—The Battle Over Proxy Contests Relies on Imaginary Soldiers
Howard Fischer and Matthew Handler of Moses and Singer write about the fatally flawed factual basis for the SEC’s proposed rule: This is more than simply an embarrassment to the rule-making process, and an affront to the credibility of the SEC. Even though the rules are, at this stage, simply proposals (there is a 60-day…
Comment from Ciara Torres-Spelliscy on SEC Proposal
Stetson law professor Ciara Torres-Spelliscy, an expert on dark money and its pernicious impact on both public and private governance, has submitted an excellent and very persuasive comment to the SEC on the proposed rules for limiting shareholder proposals. The full text is in the link below. An excerpt: [T]he rule proposed by File No….
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