We write with respect to recent developments involving the shareholder proposal process and the significant disruptive effect these developments are having on companies, boards of directors and shareholders.
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BRT has serious concerns about the governance provisions in the Federal Reserve Board’s proposal, which would require GECC’s board of directors to include a minimum of two members who are independent of GE and GECC management and independent of GE’s board of directors.
The SEC's announcement has already and will continue to significantly affect board deliberations at companies that intended to seek exclusion of stockholder proposals because the board had planned to submit a company proposal on the same topic.
Business Roundtable strongly supports important provisions included in H.R. 4413 that will reform derivatives regulation to focus more effectively on addressing potential systemic economic risk.
We appreciate the opportunity to comment on the rules proposed by the U.S. Securities and Exchange Commission (SEC or Commission) to implement Section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), as set forth in the Commission’s accompanying proposing release.
The undersigned organizations—representing hundreds of end-user companies that employ derivatives to manage risk—write in support of H.R. 1003, a bill to improve consideration by the Commodity Futures Trading Commission of the costs and benefits of its regulations and orders.
On behalf of Business Roundtable, thank you again for meeting with us on June 13 to discuss your views on the future of key regulatory matters. As you will recall, the subject of proxy advisory services was very much on the mind of attendees. Accordingly, following our meeting, I asked the Business Roundtable Corporate Governance Committee to provide me with information about their experience with the proxy advisory services. In the interest of furthering the discussion on the role and regulation of proxy advisory services, we would like to take this opportunity to share the key results with you.
The Coalition for Derivatives End-Users is pleased to respond to the request for comments by the Securities and Exchange Commission regarding its proposed rules and proposed interpretations under the Dodd-Frank Act.
June 27, 2013
We are writing in regard to the Institutional Shareholder Services (ISS) 2013 proxy voting policy change relating to board responsiveness to majority-supported shareholder proposals.
Business Roundtable urges support for H.R. 1256, the "Swaps Jurisdiction Certainty Act," which the House of Representatives is scheduled to take up today.
The undersigned organizations, which represent hundreds of thousands of businesses, small and large, from all sectors of the economy employing tens of millions of Americans, are deeply concerned by the failure of the relevant parties to reach an agreement granting regulators access to audit work papers.
When you spoke to Business Roundtable’s meeting on December 5, 2012, you offered to work to improve the effectiveness of federal regulations if we identified specific regulations of concern for review by your Administration. One serious example I want to bring to your attention concerns the implementation of the derivatives title of the Dodd-Frank Act.