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 |
