Glass Lewis announced that companies that purchase its proxy research paper will automatically have the right to submit a Report Feedback Statement (RFS) that includes the company's unedited feedback on its research. The announcement and RFS page disclosures notwithstanding, we understand that the bundled cost of the report and RFS for an S&P 500 company is $6,000 (which is out of reach for many companies, particularly now), compared to $5,500 for the report on a standalone basis. Companies will have up to 7 days after publication of Glass Lewis's report (so, most likely after an investor has already voted based on the GL recommendation) to submit an RFS. Investor clients will be directly notified, emailed and have access to the company’s feedback. Glass Lewis won't edit a company’s feedback or include its own competing statement, which the announcement notes will maintain the "independence of both parties' views."
See this additional information and these FAQs on the RFS; Davis Polk's blog; and additional resources on our Proxy Advisors page. This post first appeared in the weekly Society Alert!