January 11, 2019

“Concept Release” v. “Request for Comment”?

Is there a difference between a “concept release” and a “request for comment”? That’s what I pondered when I wrote my blog about the SEC’s open meeting on quarterly reports a few weeks ago. I think the distinction is that a “concept release” includes within it a request for comment – and a “request for comment” standing on its own is distinguished by not having all of the background information & identification of various alternatives or concepts as you see in a concept release. What’s your ten cents?

Poll: The SEC’s Concept Releases

Please take a moment to participate in this anonymous poll:

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Anti-Activism: US Chamber Announces “Aggressive & Comprehensive” Campaign

Yesterday, US Chamber President Tom Donohue delivered this speech that announced a new aggressive offensive to stop attacks on companies. Here’s an excerpt from page 7:

So today we’re announcing that the Chamber is launching an aggressive and comprehensive new campaign to meet these coordinated attacks head on. We are pursuing regulatory and legislative changes that make it easier for businesses to go and stay public … and that allow companies to focus on long-term growth. We’re working with the SEC and Congress to bring real transparency and oversight to proxy advisory firms and to reform the shareholder voting process. We’re educating directors so they are better armed to deal with public policy battles that are waged in the boardroom.

We’re vigorously opposing proposed legislation to federalize large public and private companies through the requirement of a federal charter. That’s one of the worst ideas I’ve heard in a town that knows no shortage of bad ideas. And we will work for meaningful ESG reporting that is grounded in reality and reflects the diversity of American business, across sectors and all over the country.

Broc Romanek