Advocacy: Comment Letter/Amicus Brief Archive

Since 2017, the Society has submitted more than 65 comment letters to the SEC, other federal agencies, Congress, and other governance-related entities (e.g., proxy advisors) on proposals ranging from disclosures on climate risk, cybersecurity, 10b5-1 plans, and share repurchases; pay versus performance and other compensation disclosure mandates; beneficial ownership transparency; proxy advisory firm reform; modernization of Rule 14a-8; and increasing retail shareholder participation in voting.

This page includes links to Society comment letters in response to SEC and other federal agency rulemakings, proxy advisory firms' proposed policies, and ISSB and other standard setter consultations; rulemaking petitions; testimony on pending Congressional legislation; comments on state legislation; and amicus briefs filed in notable governance and disclosure cases.

2022