April 21, 2006

SEC’s Small Business Advisory Committee Wraps Up

Yesterday, the SEC’s Small Business Advisory Committee held its final meeting. The Committee has until April 23rd to formally submit its final report with any finishing touches to the 150-page draft final report that was approved yesterday. The ball is now in the SEC’s court; Corp Fin Director John White remarked during the meeting that the SEC will have an open mind regarding the Committee’s recommendations. No timetable for that consideration was announced.

Learn more from FEI’s “Section 404 Blog,” including their two pages of notes from the meeting.

17,000 Comments on the SEC’s Executive Compensation Proposal!

With the April 10th deadline safely behind us – although comment letters will continue to dribble in, such as the forthcoming ABA letter – I thought it would be a good time to link to letters submitted from the more noteworthy market participants rather than have you slug through the nearly 17,000 letters that have poured in on this hot topic.

That number is a little misleading because the AFL-CIO was successful in having its members send in over 16,000 letters of this variety! Quite an impressive mobilization of the troops (unless software was used to bombard the SEC with a bunch of identical comment emails – wonder if that’s possible?)!

The comment letters listed below are in no particular order (and apologies to the many others that submitted letters – it’s dizzying to scroll through and pick through the list of comment letters on the SEC’s site):

1. Associations

ICGN Executive Remuneration Committee

Centre for Financial Market Integrity

Association of Corporate Counsel

New York City Bar

Securities Industry Association

US Chamber of Commerce


Business Roundtable

Society of Corporate Secretaries & Governance Professionals

2. Institutional Investors

Council of Institutional Investors

Group of 16 Institutional Investors (with $1.5 trillion in assets)

National Association of State Treasurers

Vanguard Group

Florida State Board Administration



Wisconsin Investment Board

Walden Asset Management

Connecuticut State Treasurer

British Columbia Investment Management Corporation

Amalgamated Bank Longview Funds


International Brotherhood of Electrical Workers Pension Benefit Fund

Governance for Owners

3. Compensation Consultants

Frederick W. Cook & Associates

Steven Hall & Partners

Pearl Meyer & Partners

Watson Wyatt

Mercer Human Resources Consulting

Buck Consultants


Hewitt Associates

Towers Perrin

Brian Foley Company

James Reda & Associates

Mark Van Clieaf

4. Law and Accounting Firms

Cravath, Swaine & Moore

Chadbourne & Park

Fenwick & West

Foley & Lardner

Ernst & Young



5. Other

Institutional Shareholder Services

The Corporate Library