Letters
Letters
Overview
Corporate governance means being good stewards of our beneficiaries’ capital-protecting and growing our investments.
In addition to engaging companies, we comment on regulatory policy and legislation.
We advocate for rules and regulations promoting good governance and improving transparency and safety of the market.
We advocate for state, federal and global legislation by working closely with regulatory and advisory industry bodies on updates in the governance arena to improve disclosures and raise governance standards.
We also work to oppose regulation and legislation that would weaken our rights as shareholders.
General Information
Legislative and regulatory letters
For accessible versions of files on this page, contact ADACoordinator@CalSTRS.com.
2021
Legislative letters
| Date | Addressed to | Subject |
|---|---|---|
| October 5, 2021 | Rep. Maxine Waters and Rep. Patrick T. McHenry | Support for Draft Bill that would improve governance of multi-class stock companies and require annual diversity disclosures |
Regulatory letters
| Date | Addressed to | Subject |
|---|---|---|
| September 8, 2021 | Bureau of Alcohol, Tobacco, Firearms, and Explosives | Criteria for Firearms with Attached Stabilizing Braces |
| August 18, 2021 | Bureau of Alcohol, Tobacco, Firearms, and Explosives | New Definition of Firearm Frame or Receiver |
| July 29, 2021 | Erkki Liikanen, Chair, International Financial Reporting Standards (IFRS) Foundation | Constitutional Amendments to Establish an International Sustainability Standards Board (ISSB) |
| July 12, 2021 | Public Company Accounting Oversight Board (PCAOB) | Public Input on Proposed Rule Governing Board Determinations Under the Holding Foreign Companies Accountable Act |
U.S. Securities and Exchange Commission letters
| Date | Addressed to | Subject |
|---|---|---|
| June 4, 2021 | Gary Gensler, Chair | Public Input on Climate Change Disclosures |
2020
Regulatory letters
| Date | Addressed to | Subject |
|---|---|---|
| December 22, 2020 | Erkki Liikanen, Chair International Financial Reporting Standards (IFRS) Foundation | Sustainability Reporting – Establishing a Sustainability Standards Board |
| October 5, 2020 | Employee Benefits Security Administration | Fiduciary Duties Regarding Proxy Voting and Shareholder Rights |
| September 28, 2020 | The Financial Conduct Authority | UK Proposals to Enhance Climate-related Disclosures |
| September 5, 2020 | Ontario Capital Markets Modernization Task Force | Sign-On Letter - Improving Issuers' ESG Performance & the Regulatory Structures |
| September 1, 2020 | European Supervisory Authorities (ESA) | European Supervisory Authorities Joint Consultation on ESG Disclosures |
| July 30, 2020 | U.S. Department of Labor, Jeanne Klinefelter Wilson, Assistant Secretary | DOL Amendments to How Retirement Plans Use ESG Funds |
| July 21, 2020 | Federal Reserve System, Honorable Jerome H. “Jay” Powell, Chairman, Board of Governors | Sign-on Letter Regarding Financial Regulators for Action on Climate Risk |
U.S. Securities and Exchange Commission letters
| Date | Addressed to | Subject |
|---|---|---|
| December 23, 2020 | Vanessa A. Countryman, Secretary | Adopt Nasdaq Stock Exchange Board Diversity Listing Standards |
| August 21, 2020 | Chairman Clayton and Secretary Countryman | Modernization of Regulation S-K Items 101, 103 and 105 - Follow-Up Letter |
| February 3, 2020 | Securities and Exchange Commission – Vanessa A Countryman, Secretary | Proposed Rules on Proxy Advisors and Shareholder Proposal Submission Thresholds |
2019
Legislative letters
| Date | Addressed to | Subject |
|---|---|---|
| November 18, 2019 | Committee on Financial Services | Letter of Support for the Investment Adviser Alignment Act |
| January 23, 2019 | Committee on Financial Services | H.R. 625 Promoting Transparent Standards for Corporate Insiders Act |
U.S. Securities and Exchange Commission letters
| Date | Addressed to | Subject |
|---|---|---|
| October 26, 2019 | Securities and Exchange Commission – Vanessa A Countryman, Secretary | Modernization of Reg. S-K, Items 101, 103 & 105 – Human Capital Management Metrics |
| October 15, 2019 | Securities and Exchange Commission | CII Sign-on Letter Regarding Proxy Advisor Regulation |
| September 23, 2019 | Securities and Exchange Commission – Division of Corporation Finance | Letter to Director William Hinman on Rule 14a-8 No-Action Requests |
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 |