Regulatory Matters
Glass Lewis actively engages with regulatory bodies around the world and frequently provides them perspectives from the proxy advisory industry, information on our policies and procedures, and input on pending regulations.
Any additional regulatory-related questions can be directed to regulatory@glasslewis.com.
Statements, Comments & Resources
Glass Lewis Statements and Correspondence
- Response to the SGX RegCo (Singapore Exchange Regulation) Consultation Paper on Facilitating Shareholder-Requisitioned Meetings
- Response to the Consultation Draft for a 5th Edition of the ASX Corporate Governance Council Principles and Recommendations
- Response Letter to Multiple State Treasurers (June 2023)
- Response Letter to Multiple States’ Attorneys General Re: Proxy Advisory Issues (January 2023)
- Comment Letter to U.S. Securities & Exchange Commission on Enhanced Disclosure of ESG Issues (August 2022)
- Comment Letter to U.S. Department of Labor on Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights (December 2021)
- Comment Letter to U.S. Securities & Exchange Commission on Reporting of Proxy Votes (December 2021)
- Comment Letter to Australian Treasury Consultation on Transparency of Proxy Advice (June 1, 2021)
- Comment Letter to U.S. Department of Labor On Fiduciary Duties Regarding Proxy Voting and Shareholder Rights (October 5, 2020)
- Comment Letter to Ontario Markets Modernization Taskforce Regarding Consultation Report – July 2020 (September 7, 2020)
- Comment Letter to SEC Regarding Amendments to Exemptions from the Proxy Rules for Proxy Voting Advice (February 3, 2020)
- Comment Letter to Office of Management and Budget (OMB) on SEC Proposed Amendments to Exemptions from the Proxy Rules for Proxy Voting Advice (January 7, 2020)
- Statement on SEC August 2019 Guidance (August 22, 2019)
- Letter on SEC Roundtable on the Proxy Process (November 14, 2018)
- Letter to Senate Banking Committee (June 1, 2018)
- Statement to the House Financial Services Committee’s Subcommittee on Capital Markets and Government Sponsored Enterprises (May 17, 2016)
- Letter to SEC on “proxy solicitation” (June 30, 2014)
Investor Perspectives on Proxy Advisor Regulation
- Council of Institutional Investors Letter to the SEC requesting extension of comment period (November 15, 2019)
- Council of Institutional Investors Letter to the SEC requesting underlying data and supplementary information (November 14, 2019)
- Council of Institutional Investors Fact Sheet on Proxy Advisory Firms and Shareholder Proposals (Nov. 5, 2019)
- Council of Institutional Investors Letter to the SEC on claims of proxy advisor inaccuracy (October 24, 2019)
- Council of Institutional Investors and 60 Institutional Investors’ Letter to the SEC on the Commission’s August Guidance (October 15, 2019)
- Investment Company Institute Letter on SEC Roundtable (March 15, 2019)
- Investment Adviser Association Letter on SEC Roundtable (December 31, 2018)
- Nell Minow, Harvard Law School Forum on Corporate Governance and Financial Regulation (March 2, 2018)
Government Reports & Pronouncements
United States
- Securities and Exchange Commission Guidance on Investment Advisers’ use of Proxy Advisors (August 21, 2019)
- Securities and Exchange Commission Interpretation and Guidance Regarding the Applicability of the Proxy Rules to Proxy Voting Advice (August 21, 2019)
- Transcript of the Securities and Exchange Commission Roundtable on the Proxy Process (November 15, 2018)
- SEC Staff Legal Bulletin No. 20 on Proxy Voting (June 30, 2014)
- Government Accountability Office Report on Proxy Advisory Firms (November 15, 2016)
Global
- Securities and Exchange Board of India Circular – Procedural Guidelines for Proxy Advisors (August 3, 2020)
- Capital Markets Modernization Taskforce (Ontario, Canada) – Consultation Report (July 2020)
- Securities and Exchange Board of India Report of Working Group on Issues Concerning Proxy Advisors (July 29, 2019)
- Canadian Securities Administrators National Policy 25-201 Guidance for Proxy Advisory Firms (April 30, 2015)
- European Securities and Markets Authority Recommendation for Proxy Advisors to Develop a Code of Conduct (2013)
Proposed Rules and Final Regulations
- U.S. SEC Exemptions from the Proxy Rules for Proxy Voting Advice (July 2020)
- U.S. SEC Supplemental Guidance (July 2020)
- U.S. SEC August 2019 Guidance
- U.S. SEC Proposed Amendments to Resubmission Thresholds (November 2019)
- U.S. SEC Proposed Amendments to Exemptions for Proxy Rules (November 2019)
- SRD II Resource Hub
Academic Studies
- Li, Tao, “Outsourcing Corporate Governance: Conflicts of Interest Within the Proxy Advisory Industry,” 64 Mgmt. Sci. 2951 (2018).
- Dent, Jr., George W., “A Defense of Proxy Advisors,” 2014 Mich. St. L. Rev. 1287 (2014).
- Choi, Stephen; Fisch, Jill E.; and Kahan, Marcel, “The Power of Proxy Advisors: Myth or Reality?,” 59 Emory Law Journal 869 (2010).
Regulatory Matters Blog
Glass Lewis Submits Response to Euronext Consultation on the Introduction of an Irish Corporate Governance Code
Glass Lewis recently submitted feedback to Euronext in response to a consultation paper (PDF) on the adoption of an Irish Corporate Governance Code (the “Code”). Background The Irish and UK stock exchanges have traditionally been [...]
Glass Lewis Submits Response to NZX Consultation on Director Independence
As part of a wider review of its corporate governance settings relating to director independence, New Zealand's Exchange (NZX) recently held the second stage of a consultation (PDF) on proposed amendments to the NZX Listing [...]
SRI Label 3.0: Stricter Rules for France’s Socially Responsible Investments
To access this article in French, click here: Accès en français France’s ground-breaking socially responsible investment (SRI) label enables retail investors to choose financial savings instruments that incorporate [...]
UK FCA Consultation: Primary Markets Effectiveness Review
Update 13 June 2024: This post has been updated to confirm that, despite stakeholders publicly voicing their concerns regarding the proposed rules, it appears the FCA will proceed with approval. It is expected that the [...]
Glass Lewis Submission to SGX RegCo Consultation on Shareholder-Requisitioned Meetings
Glass Lewis recently submitted feedback to SGX RegCo (Singapore Exchange Regulation) in response to a consultation paper on facilitating shareholder-requisitioned meetings. In particular, the consultation revolves around issuers providing reasonable assistance in facilitating shareholder-requisitioned meetings [...]
SEC Rules Set New Baseline for Corporate Climate Disclosures
Climate-related impacts like rising sea levels, massive fires and increasing emissions stand to put many companies at risk. However, the growing tide of regulations has the potential to lift all boats (or at least the [...]