General Information

Legislative and Regulatory Letters

2019

Legislative Letters

Date Addressed To Subject
January 23, 2019 Committee on Financial Services H.R. 625 Promoting Transparent Standards for Corporate Insiders Act

2018

Regulatory Letters

Date Addressed To Subject
September 10, 2018 Public Company Accounting Oversight Board PCAOB Draft Strategic Plan 2018-22

Stock Exchange Letters

Date Addressed To Subject
November 20, 2018 New York Stock Exchange Request NYSE to Amend Listing Standards on Multi-class Shares – Sunset Provisions
November 20, 2018 Nasdaq Request Nasdaq to Amend Listing Standards on Multi-class Shares – Sunset Provisions
April 30, 2018 Tokyo Stock Exchange and Financial Services Agency Revision of Japan’s Corporate Governance and Stewardship Codes
April 25, 2018 Singapore Stock Exchange Proposed Listing Framework for Dual Class Share Structures
April 3, 2018 Monetary Authority of Singapore Proposed amendments to the Singapore Exchange Listing Rules and Corporate Governance Code

U.S. Securities and Exchange Commission Letters

Date Addressed To Subject
November 30, 2018 Securities and Exchange Commission Roundtable on the Proxy Process, File Number 4-725
February 1, 2018 Securities and Exchange Commission Section 1504 of Dodd-Frank Act Disclosure of Payments by Resource Extraction Issuers

2017

Legislative Letters

Date Addressed To Subject
November 9, 2017 Committee on Financial Services Sign-on Letter regarding Proposed legislation Relating Proxy Advisory Firms
June 5, 2017 United States House of Representatives Letter of opposition to the Financial CHOICE Act of 2017
May 17, 2017 United States House of Representatives Sign-on Letter to CII’s opposition to the Financial CHOICE Act of 2017
April 25, 2017 United States House of Representatives Letter to Maxine Waters, Ranking Member, House Committee on Financial Services
January 10, 2017 United States House of Representatives H.R. 78, SEC Regulatory Accountability Act

Regulatory Letters

Date Addressed To Subject
December 29, 2017 Sustainability Accounting Standards Board Financial Sector: Asset Management & Custody Activities
December 15, 2017 International Ethics Standards Board for Accountants Code Pertaining to the Offering and Accepting Inducements by Auditors
September 9, 2017 Public Company Accounting Oversight Board Proposed Auditing Standard for Auditing Accounting Estimates, Including Fair Measurements
September 9, 2017 Public Company Accounting Oversight Board Proposed Amendments to Auditing Standards for Auditor’s Use of the Work of Specialists
August 31, 2017 MSCI Equity Index Committee MSCI Consultation - Non-voting Shares
August 9, 2017 U.S. Environmental Protection Agency EPA Oil and Natural Gas Sector Emission Standards
July 13, 2017 Financial Services Agency Japanese Disclosure System Questionnaire
May 6, 2017 Financial Services Agency Principles for Responsible Institutional Investors, Japan Stewardship Code

Stock Exchange Letters

Date Addressed To Subject
August 17, 2017 Hong Kong Exchanges and Clearing Limited New Board on HKEX, Changes to GEM and Main Board Listing Rules
August 1, 2017 Nasdaq Nasdaq Shareholder Approval Rules Rule 5635(d)
April 14, 2017 Singapore Exchange Limited SGX's Public Consultation on Dual Class Share Structure

U.S. Securities and Exchange Commission Letters

Date Addressed To Subject
December 4, 2017 Securities and Exchange Commission Sexual Harassment and Misconduct
August 23, 2017 Securities and Exchange Commission SEC PCAOB Audit Report Adoption
July 10, 2017 Securities and Exchange Commission Human Capital Management Disclosures Rulemaking Petition
July 6, 2017 Securities and Exchange Commission Human Capital Management Coalition
June 27, 2017 Securities and Exchange Commission Human Capital Management Coalition
March 22, 2017 Securities and Exchange Commission Pay Ratio Final Rule Implementaion
January 9, 2017 Securities and Exchange Commission S7-24-16, Proposed SEC Rule, Universal Proxies

2016

Legislative Letters

Date Addressed To Subject
June 13, 2016 House Committee on Financial Services HR 5311 – Regulation of Proxy Advisory Firms

Regulatory Letters

Date Addressed To Subject
December 15, 2016 Regierungs-kommission – German Commission German Corporate Governance Code (sign-on)
August 12, 2016 Public Company Accounting Oversight Board Auditor Reporting – Enhancements  - Expanded Reporting
May 16, 2016 International Auditing and Assurance Standards Board Professional Skepticism
April 18, 2016 Bundestag – Parliament of the Federal Republic of Germany (Kunast) Corporate Governance standards (sign-on)
April 18, 2016 Bundestag – Parliament of the Federal Republic of Germany (Hirte) Corporate Governance standards (sign-on)
January 14, 2016 International Corporate Governance Network Global Stewardship Code

Stock Exchange Letters

Date Addressed To Subject
November 29, 2016 Tokyo Stock Exchange Increasing Flexibility of Earnings Reports and Quarterly Earnings (sign-on)
February 18, 2016 Nasdaq Improve Shareholder Approval Rules
February 5, 2016 Taiwan Stock Exchange Stewardship Principles

U.S. Securities and Exchange Commission Letters

Date Addressed To Subject
November 18, 2016 Securities and Exchange Commission Disclosure Update and Simplification (Regulation S-K)
October 31, 2016 Securities and Exchange Commission Subpart 400 of Regulation S-K Disclosure Requirements
July 21, 2016 Securities and Exchange Commission S7-06-16 Business and Financial Disclosure Required by Regulation S-K
July 21, 2016 Securities and Exchange Commission Climate Risk Disclosures Required by Regulation S-K (Sign-on)
April 14, 2016 Securities and Exchange Commission Transfer Agent Regulations
March 10, 2016 Securities and Exchange Commission Market Alternatives (Exchange), Investors’ Exchange (IEX)
March 8, 2016 Securities and Exchange Commission Payments by Resource Extraction Issuers

2015

Regulatory Letter

Date Addressed To Subject
August 27, 2015 Public Company Accounting Oversight Board Form AP Auditors Signature

Commands