The Comment Letter Cornucopia

The deadline for comments on the SEC concept release ended October 20, and as reliable as Old Faithful, there was a gusher of letters pouring into the SEC in the last few days:  15 on Oct. 18; 30 on October 19; and 68 on October 20.  More continue to dribble in.  I'll be particularly interested in seeing the Society of Corporate Secretaries and Governance Professionals' letter when it arrives. I've got my work cut out for me.  So much to read, digest and tell you about.

Still, it's not as many comment letters as I would have expected -- for the possible overhaul of the U.S. proxy voting system and maybe the single most significant influence on the corporate governance of public companies other than state law.  The number of comments received pales next to "proxy access".  The SEC staff does note that there have also been about 167 submissions of the "form letter" variety to the effect that "the U.S. Chamber of Commerce and the Business Roundtable are pressuring the SEC to rewrite the U.S. proxy system. These groups want companies to have greater control over proxy voting by shareholders. ... I urge you [the SEC] to consider the interests of shareholders before making any changes to the existing proxy system that generally works well."  But numbers aren't everything. This is difficult stuff.  We are not starting from a clean slate.  There are people with vested economic interests at work.  Tough policy decisions with worries of unintended consequences.

Here's a pet peeve of mine.  Why do some submit comment letters using the employer's letterhead when the letter is not on behalf of the employer? Academic professors seem to be the most notorious.  Do they first ask permission of the president of the university or law school?  But publicity is good (for the school), unless the person says something really stupid. 

The SEC's website doesn't allow you to search the comment letters, but I've made it simple.  Just try this: