February 12, 2010
Doing the Math: How Many Proxy Access Comment Letters This Decade?
In a recent speech, SEC Chair Schapiro said “we are nearing a vote” on proxy access rule, but she did not provide a timetable. Last month, I conducted a poll on this blog regarding how many comment letters have been submitted to the SEC on its various reiterations of proxy access proposals since 2003 (the total does include form letters). The poll results were:
– 5% thought there were between 100-500
– 4% between 500-1000
– 18% between 1000-3000
– 28% between 3000-10,000
– 26% between 10,000- 50,000
– 20% over 50,000
Well, the last category is the winner. There have been over 50,000 comment letters submitted to the SEC on proxy access over the past 7 years. Unbelievable. That’s a lot of hard labor.
Here is the math that leads us to this conclusion:
1. 2003 proposal – The SEC received approximately 500 individually signed comments plus form letters from 12,500 others. The SEC held a roundtable in February 2004, after which it received approximately 200 additional individually-signed comments, plus an additional 2,000 form letters.
2. 2007 proposal (alternative 1) – The SEC received approximately 200 comments on this alternative, plus 9,300 form letters.
3. 2007 proposal (alternative 2) – The SEC received approximately 600 comments on this alternative, plus 26,000 form letters.
4. 2009 proposal – The SEC has received over 500 comments so far, but not much in the way of form letters this time around. The latest extension for this proposal has brought in more than 40 letters.
So the total of these is roughly 51,800 comment letters. And counting…
In this podcast, John Palizza (who writes the “Investor Relations Musings” blog) enlightens us with some investor relations fundamentals, including:
– I always thought that investor relations was like advertising – very difficult to measure in its impact. How have people attempted to gauge what investor relations officers do?
– What does the research say about the impact of investor relations?
– Other than making sure investors understand the company’s financial measures, what can investor relations officers do?
More on “The Mentor Blog”
We continue to post new items daily on our blog – “The Mentor Blog” – for TheCorporateCounsel.net members. Members can sign up to get that blog pushed out to them via email whenever there is a new entry by simply inputting their email address on the left side of that blog. Here are some of the latest entries:
– Rule 163 Proposal: Some Have a Beef
– Canadian Companies Show Renewed Interest in US Capital Markets
– Regulation FD: Can You Walk Analysts Down From Too Much Optimism?
– Survey: Corporate Governance and IPOS
– Jail Time: SEC Goes After Scofflaw
– Broc Romanek