Legal Efforts to Hobble Shareholder Rights

We are in an anti-democratic moment. People with money and power refuse to heed those who have neither. This is true in Washington. But, it is also true in statehouses where state officials try to intimidate into non-action and silence investors who believe sustainability is key to long-term investment success.  

There is nothing “free market” about this effort. Instead, it is an attempt to bolster the fossil fuel industry at the expense of shareholder prerogatives. 

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2025 Update on SEC Rules for Shareholder Proposals

In order to help companies and investors determine whether a shareholder proposal qualifies to appear on the proxy statement under SEC Rule 14a-8, the SEC has developed a process to allow companies to inquire in advance whether a proposal must be included. The “no action” process is an informal review process through which the SEC staff advises companies and their investors on whether the SEC staff would recommend enforcement action if a company fails to include a submitted shareholder proposal on its annual proxy statement. 

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NAM's SEC Lawsuit Undermines Shareholder Rights

In May 2023, the National Association of Manufacturers (NAM) successfully filed a motion to intervene in a federal case brought by the anti-ESG group the National Center for Public Policy Research (NCPPR) against the Securities and Exchange Commission (SEC), challenging a shareholder resolution No Action determination. The NAM motion opened a broader challenge to the SEC’s authority to provide guidance regarding whether shareholder resolutions could be allowed on a company’s proxy for a vote, claiming that this process violates principles of corporate First Amendment rights enshrined in the Citizens United ruling.

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SCOTUS Decision Could Scuttle Regulatory Agencies and Shareholder Rights

The modern administrative system was set up in recognition of the needs of a technologically developed society where the lives of citizens are affected by dozens and dozens of complex areas. From air pollution, to drugs, the internet, transportation, education, chemicals, railroads, airwaves, consumer protection, and health, agencies set the rules of the road for some of the most important areas of our lives.

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2024 Update on Shareholder Rights Legal and Policy Developments

This year proxy and shareholder proposal rules and practice are evolving to create greater accountability and efficiency. Simultaneously, so called anti-ESG efforts are pressing a more disruptive policy agenda that could eviscerate the rights of share owners to file and vote on environmental and social proposals.

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What the SEC's Mandatory Climate Disclosure Proposal Means for Investors and Market Protection

The adage “you can’t manage what you don’t measure” is a sound argument for measuring and assessing climate risks, which cost the world over $313 billion in 2022 alone. Investors have expressed their resounding support, including more than 600 investors who signed the 2022 Global Investor Statement urging governments to address climate risks through mandatory disclosure.

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2023 Update on SEC Shareholder Proposal Rules and Guidelines

Recent efforts of the Securities and Exchange Commission (SEC) Staff to create a more objective and efficient process for handling shareholder proposals have borne fruit in 2023, resulting in a 30 percent reduction in company-filed challenges to shareholder proposals.  Clearer guidelines from the Staff have made it possible for shareholders to draft more defensible proposals.

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ESG Data Helps Assess Value, Potential Returns and Manage Investment Risk

Institutional investors have been paying attention to environmental, social and governance risk factors long before it was “ESG.” Without fanfare or agenda, these long-term investors took notice of weak governance practices that led to corruption, friction with workforces that led to strikes and factories that spewed toxins into rivers leading to lawsuits from those who lived downstream.

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Republican Efforts to Limit ESG Investing are Anti-Capitalist

There is a cohort of elected officials in the United States presently engaged in an anti-capitalist crusade against free-market principles. No, they are not socialists. They are congressional Republicans, and they are attempting to prevent financial institutions from allocating capital in accordance with investor preferences and risk management principles. This attempted crackdown is purely ideological in nature — it is an exercise in political pressure to force a gross government overreach into U.S. capital markets.

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New Universal Proxy Rule Will Democratize Director Elections

In November 2021, the SEC adopted final rules that will require parties in a contested corporate director election to use universal proxy cards for shareholder meetings held after August 31, 2022. Under the new rules, both the company and any shareholder seeking to elect a slate of director candidates at a shareholder meeting will be required to use proxy cards that include the names of all director nominees presented for election at the meeting.

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