In this memo, Pay Governance examines comment letters from investors that were submitted to the SEC in response to the agency’s proposed expansion of Non-Accelerated Filer status and Emerging Growth Company accommodations, along with submissions related to the SEC’s Executive…

If you’ve been following the nifty “comment letter tracker” for the SEC’s semiannual reporting proposal put together by Professor Tzachi Zach, you can see that the number of comments are very high – and that a large percentage of comment…

This paper by Professors Jonathan Macey and Nathan Atkinson – “Mirroring The Market: Passive Voting And Outcome Non-Neutrality” – argues that current mirror-voting proposals are not truly neutral. Uniform mirroring inadvertently lowers voting thresholds and subsidizes quorums. The authors propose…

I’ve been around long enough to witness the advent of personal computers, emails, the Internet and cell phones – and now we have AI to contend with. Each has had a number of mind-blowing consequences for corporate culture. Still, I…

This memo from PwC’s Matt DiGuiseppe, Gregory Johnson and Ariel Smilowitz argues that the new shareholder engagement paradigm is more complex than before – and that directors and shareholders will be engaging more directly going forward. Here’s the related set…