Society Views & Comment Letters

Society comment letters in response to SEC and other relevant agency rulemakings and proxy advisory firm policy development activities, Congressional testimony on proposed and pending legislation, publications on topical issues and much more.

By leveraging the Society’s Securities Law Committee, Corporate Practices Committee, and Sustainability Practices Committee, the Society marshals the best-informed and legally sophisticated perspective available for the SEC, Congress and other key governance-related entities. Our National Committee structure provides in-house counsel and ESG/sustainability executives with best-in-class insight into the policy making process and the ability to influence those efforts.  


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2022

Society Supplemental Comment Letter: The Enhancement and Standardization of Climate-Related Disclosures for Investors | November 2022

Society Comment Letter: Request for Delay in Compliance Deadline for Pay Versus Performance Disclosure | October 2022

Society Amicus Brief: U.S. Chamber & Business Roundtable vs. SEC (Proxy Advisors) | September 2022

Society Comment Letter: Substantial Implementation, Duplication, and Resubmission of Shareholder Proposals Under Exchange Act Rule 14a-8 | September 2022

Society Supplemental Comment Letter: The Enhancement and Standardization of Climate-Related Disclosures for Investors | September 2022

Society Comment Letter: 2022 ISS Global Benchmark Policy Survey | August 2022

Society Supplemental Comment Letter: Proposed Rule: Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure | August 2022

Society Supplemental Comment Letter: Proposed Standards: ISSB Exposure Drafts: General Requirements for Disclosure of Sustainability-related Financial Information; Climate-related Disclosures | July 2022

Society Comment Letter: The Enhancement and Standardization of Climate-Related Disclosures for Investors | June 2022

Society Comment Letter: Proposed Rule: Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure | May 2022

Society Comment Letter: The Enhancement and Standardization of Climate-Related Disclosures for Investors | April 2022

Society Comment Letter: Modernization of Beneficial Ownership Reporting | April 2022

Society Comment Letter: Share Repurchase Disclosure Modernization | April 2022

Society Comment Letter: 10b5-1 Plans and Insider Trading | April 2022

Society Comment Letter: Reopening of Comment Period for Pay Versus Performance | March 2022

Society & NIRI Comment Letter: SEC on Proxy Distribution Fees | February 2022


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