Doug ChiaSep 16, 2022SEC (finally) jumps into ESG fund fracasThe SEC has taken the first steps to create some much-needed semblance of order and structure in the ESG investment industry.
Doug ChiaAug 30, 2022Comment Letter: SEC Proposal on Investment Company NamesSEC comment letter on proposed rules on Investment Company Names.
Doug ChiaAug 16, 2022Comment Letter: SEC Proposals on ESG Fund Names and DisclosuresI support the Commission’s efforts to enhance the level and quality of disclosure required by funds that claim to invest based on ESG...
Doug ChiaDec 14, 2021Staff Legal Bulletin 14L and the Significant Social Policy Exception: A Possible Solution?Determining what is a "significant social policy issue" under Rule 14a-8(i)(7) desperately needs a multi-pronged test.
Doug ChiaDec 1, 2021Staff Legal Bulletin 14L: No More NexusShouldn’t there be a nexus between a shareholder proposal and the company at which it is filed? The answer to this question seems obvious.
Doug ChiaNov 10, 2021(First in a Series of) Thoughts on Staff Legal Bulletin No. 14LThe term “significant policy issue” doesn’t appear anywhere in Rule 14a-8. So, where does this exception come from?
Doug ChiaSep 28, 2021The Virtual Annual Meeting Shareholder Proposals!The SEC staff appears to have flipped the script on shareholder proposals about virtual shareholder meetings.
Doug ChiaApr 19, 2021When Disclosure Is the Better Part of Valor: Lessons From the AT&T Regulation FD Enforcement ActionThe AT&T enforcement action shows the SEC continues to examine corporate strategies to influence securities analysts’ quarterly estimates.
Doug ChiaApr 7, 2020COVID-19 Annual Meeting and SEC Disclosure Checklist and Best Practices Reference Guide ProxyAnalytics and SoundboardGovernance have published a COVID19 Annual Meeting & SEC Disclosure Checklist & Best Practices Reference Guide.
Doug ChiaDec 2, 2019Say it ain't so, Broc. Say it ain't so!A fond farewell to Broc Romanek, pillar of the corporate securities and governance community.
Doug ChiaSep 9, 2019The SEC's Proxy Advisory Firm GuidanceWhat really needs to happen is throwing sunshine on the funds that heavily rely on PAFs. That's where some novel disclosure requirements...