The full text is linked below. From the introduction and summary: We begin with three key points as context for this comment, all with one theme: the superiority of market tests over regulation whenever possible (unless there is a collective choice problem distorting the market, which is not the case here). 1. The determining issue…
Tag: sec
James McRitchie: Proxy Roundtable Comment Letter
Corpgov.net‘s James McRitchie, one of the most knowledgeable and effective individual investors, has submitted an exceptionally thoughtful and well-informed comment to the SEC. Many thanks for his gracious permission to publish it in full. Final comment letter to the SEC on Shareholder Proposals, re File Number 4-725, including 11 recommendations highlighted on bold. Mr. Brent…
Protecting the Shareholder Proposal Process — As You Sow
Rosanna Weaver at As You Sow writes about the shareholder proposal section of last week’s SEC Proxy Roundtable. An excerpt: Looking back over time, the shareholder resolution system works. So why these discussions again? In great part, it is because the system has been effective in raising social and environmental issues to the fore and…
VEA Vice Chair Nell Minow on Motley Fool Money Podcast: Shareholder Rights and Stan Lee
VEA Vice Chair Nell Minow appears on the Motley Fool Money podcast to discuss the SEC’s Proxy Roundtable, Stan Lee as a brand genius, and more.
Minerva Analytics: Comment on SEC Proxy Roundtable
From Minerva Analytics’ comment to the SEC for the Proxy Roundtable (link to the full comment below): We note the activities of the immensely vocal, but narrow, anti-ESG and governance lobby which continues to ignore and disrespect the beliefs and preferences of capital providers. Investors use governance research and vote execution services to legitimately help…
ISS Comment Letter to the SEC on the Proxy Process
ISS has filed its comment letter for the Proxy Roundtable with the SEC. Some highlights: They respond to those who claim that proxy advisors are not regulated and those who claim they control the proxy voting decisions of their clients: “As a registered investment adviser, we have a fiduciary obligation to our clients to provide…
So The SEC’s Decision to Rescind the 14-Year Old Proxy Advisory Rulings Was Apparently a Whim With No Documentation
The government in general and the regulatory agencies and independent commissions in particular have a heavy burden of transparency and documentation to justify their authority to promulgate regulations and issue judgments that have the force of law. Because they are not subject to the electoral oversight of the legislative bodies, there is a huge body…
More Bogus Anti-Shareholder Propaganda to Fuel the Upcoming SEC Proxy Roundtable
The SEC’s roundtable on the proxy system is scheduled for next month, and so articles that look suspiciously like plants from the CEO-funded fake dark money front group Main Street Investors Coalition are popping up like a sock puppet chorus. In Forbes, Ike Brannon, a consultant affiliated with the Koch-funded Cato Institute and member of…
Sarah Wilson on the Four Billion Reasons Not to Mess with Proxy Plumbing
Our deepest thanks to Sarah Wilson of Minerva Analytics for allowing us to post her thoughtful essay on the SEC’s proxy plumbing initiative, and for her support in our efforts to keep the Main Street Investors Coalition and their various other corporate-funded fake front groups from spreading disinformation about shareholders and proxy advisors. Here is…
SEC Commissioner Heather Peirce: My Beef with Stakeholders
SEC Commissioner Heather Peirce spoke about her concerns when people talk about stakeholders. She recognizes that corporations have many stakeholders and are accountable to them in different ways. While her tone is condescending and dismissive at times, we are also concerned that stakeholder rhetoric can be misapplied, as with the state “stakeholder” laws adopted specifically…
