Council of Institutional Investors

Correspondence, Legal Briefs and Testimony

Generally excluded from this page are letters to individual companies urging the implementation of majority-supported shareholder proposals, inquiring about the status of “zombie” directors (those who remain on the board after having failed to obtain majority support), and/or seeking a majority standard for uncontested director elections. Please contact us for copies of those letters. For correspondence prior to 2021 please click here.

  
June 24, 2022 CII letter to SEC on clawback proposal
June 9, 2022 CII letter to SEC on SPAC reform proposal
June 2, 2022 CII letter to Senate Banking Committee on JOBS Act 4.0
May 19, 2022 CII letter to SEC Generally Supporting SEC's Climate Disclosure Proposal, with Some Revisions
May 9, 2022 CII letter to SEC on Cyber Security
April 13, 2022 CII letter to Chair of Committee on Financial Services on Russia sanctions
April 8, 2022 CII letter to SEC on proposal to modernize beneficial ownership reporting
April 7, 2022 CII letter to SEC on proposal on Private Fund Advisers
April 5, 2022 CII letter to Chair and Ranking Member of Committee on Financial Services on Multi-class Bill
See also letter from California State Teachers’ Retirement System
March 31, 2022 CII letter to SEC on proposal to enhance buyback disclosures
March 24, 2022 CII letter to SEC on Rule 10b5-1
Feb. 24, 2022 CII letter to SEC on Pay Versus Performance
Feb. 24, 2022 CII letter to SEC on Reg Flex Agenda
Feb. 24, 2022 CII joint brief to 5th Circuit in support of SEC and Nasdaq board diversity disclosure
Feb. 14, 2022 CII letter to European Commission on Dual-Class Stock and SPACs
Attachment: CII response to Public Consultation on Listing Act
Feb. 10, 2022 CII letter to PCAOB on Advisory Groups
Dec. 24, 2021 CII letter to SEC on Proxy Voting Advice Proposal
Dec. 14, 2021 CII & CFA Institute joint letter to SEC on amendments to Form N-PX
Dec. 9, 2021 CII letter to SEC on Nasdaq SPAC proposal
Dec. 2, 2021 CII letter to DOL on ESG and proxy voting proposal
Attachment 1: CII letter to DOL on Fiduciary Duties Regarding Proxy Voting and Shareholder Rights
Attachment 2: CII letter to DOL on Financial Factors in Selecting Plan Investments
Nov. 18, 2021 CII letter to SEC on clawback proposal
Nov. 16, 2021 CII comment letter to ISS on proposed benchmark policy changes
Nov. 10, 2021
CII amicus brief in Assad v. E.Merge Technology Acquisition Corp. et al highlighting misalignment of interests in SPACs
Nov. 2, 2021 CII letter to Chairman and Ranking Member of Investor Protection, Entrepreneurship and Capital Markets Subcommittee
Oct. 28, 2021 CII letter to SEC on private fund advisers
Oct. 28, 2021 CII letter to PCAOB on supervision of audits proposal
Oct. 21, 2021 CII letter to SEC on Nasdaq direct listing proposal
Oct. 12, 2021 CII letter to Chairwoman and Ranking Member of Committee on Financial Services
Oct. 6, 2021 CII letter to Blue Apron commending recapitalization to one share, one vote structure
Oct. 1, 2021 CII letter to Chairwoman and Ranking Member of Committee on Financial Services
See also letters from CII Members and other organizations: Americans for Financial ReformCalifornia Public Employees’ Retirement SystemCalifornia State Teachers’ Retirement SystemConsumer Federation of America, Federated HermesHealthy Markets AssociationLos Angeles County Employees Retirement Association, North American Securities Administrators AssociationOffice of the New York State Comptroller, Ohio Public Employees Retirement System, Public CitizenRailpen, Washington State Investment Board
Sept. 27, 2021 CII letter to IASB on agenda consultation
Sept. 24, 2021 CII amicus brief in Interfaith Center on Corporate Responsibility, James McRitchie and As You Sow v. United States Securities and Exchange Commission
Sept. 16, 2021 CII letter to FASB on agenda consultation
Sept. 14, 2021 CII letter to U.K. FCA on dual-class share structures
Aug. 19, 2021 CII letter to SEC on Reg Flex Agenda  
July 28, 2021 CII letter to Chairwoman and Ranking Member of Committee on Financial Services
July 15, 2021 CII letter to IFRS Foundation on Proposed International Sustainability Standards Board
June 24, 2021 CII letter to the PCAOB on determinations under the Holding Foreign Companies Accountable Act 
June 14, 2021 CII letter to Speaker and Minority Leader regarding amendment to H.R. 1187
June 11, 2021 ClI letter to SEC on climate change disclosures
June 10, 2021 Prepared Written Remarks to SEC IAC on Rule 10b5-1
June 2, 2021 CII letter to SEC on finalizing universal proxies for contested elections
May 27, 2021 CII letter to SEC on Nasdaq proposal relating to PCAOB inspections
May 26, 2021 CII letter to TSY/AU on proxy advice
May 26, 2021 CII letter to DOL on ESG & proxy rules
May 5, 2021 CII letter to SEC on Holding Foreign Companies Accountable Act Disclosure
April 27, 2021 CII letter to Chairman and Ranking Member of Banking Committee on S.J. Res. 16.
April 22, 2021 CII letter to SEC Chair
Attachment: CII letter to SEC on agenda
April 22, 2021 CII letter to SEC on agenda
April 22, 2021 CII letter to Chair and Ranking Member of Committee on Financial Services on H.R. 1277
April 1, 2021 CII letter to SEC on Nasdaq diversity proposal
March 25, 2021 CII letter to SEC on Nasdaq proposal relating to SPACs
March 18, 2021 CII letter to Senate Banking Committee supporting the SEC as Investor Advocate Act of 2021
Attachment: draft of the SEC as Investor Advocate Act of 2021
March 18, 2021 CII letter to SEC on Rule 144
Feb. 25, 2021 CII letter to SEC on NYSE proposal relating to SPACs
Feb. 18, 2021 CII letter to SEC on Nasdaq proposal relating to restrictive market companies
Feb. 17, 2021 CII letter to UK Treasury on dual-class share structures
Feb. 1, 2021 CII letter to FTC on premerger notification proposal
Jan. 15, 2021 Joint amicus brief in Nasdaq v. SEC
Jan. 13, 2021 CII letter to SEC on Nasdaq proposal relating to direct listings 
Jan. 7, 2021 CII letter to SEC on Nasdaq proposal relating to SPACs