Older Correspondence

Dec. 30, 2020 CII letter to the SEC supporting Nasdaq's Proposed Listing Standard on Board Diversity
Dec. 17, 2020 CII letter to IFRS Foundation on Sustainability Reporting
Attachment: Responses to Questions for Consultation in the IFRS Foundation Consultation Paper on Sustainability Reporting
Dec. 11, 2020 Joint letter to the Treasury Department's Office of Foreign Assets Control on the Presidential Executive Order on Chinese Companies with Military Ties
Dec. 11, 2020 CII letter to Roblox regarding its adoption of a seven-year time-based sunset
Dec. 9, 2020 CII letter to Affirm Holdings regarding its adoption of a seven-year time-base sunset
Dec. 9, 2020 CII letter to Wish regarding its adoption of a seven-year time-based sunset
Dec, 3, 2020 CII letter to DoorDash on time-based sunset provisions for super-voting share classes
Dec, 3, 2020 CII letter to SEC on auditor independence rules
Nov. 9, 2020 CII letter to Brazilian Securities Commission on dual-class stock
Nov. 6, 2020 Joint letter to SEC on fund expense disclosures
Oct 13, 2020 CII amicus brief in Institutional Shareholder Services v. SEC
Oct. 8, 2020 CII letter to SEC on Nasdaq direct listing proposal
Sept. 30, 2020 CII letter to SEC on Nasdaq restrictive market proposals
Sept. 25, 2020 CII letter to SEC on agenda
Sept. 24, 2020 CII letter to DOL on Fiduciary Duties Regarding Proxy Voting and Shareholder Rights  
Sept. 17, 2020  CII letter to SEC on Form 13F proposal
Sept. 8, 2020 CII Petition for Review of an Order and Brief in Opposition to Motion to Lift the Automatic Stay on NYSE direct listings
Sept. 4, 2020 Joint letter to SEC on proposed changes to Rule 14a-8
Sept. 3, 2020 CII letter to Palantir Technologies on adding a dual-class stock sunset provision
Aug. 31, 2020 CII notice of intention to petition SEC for review of order expanding direct listings
Aug. 19, 2020 Written remarks of CII’s General Counsel at the SEC 14a-8 Stakeholder Meeting
Aug. 11, 2020 CII letter to Senate Banking Committee on H.R. 5084
Aug. 6, 2020 Joint letter to SEC on potentially finanlizing universal proxy rule
Aug. 4, 2020 CII letter to SEC on NASDAQ Hearings Panel proposed rule changes
Aug. 3, 2020 Joint letter to SEC staff regarding Rule 14a-8 stakeholder meeting
July 29, 2020 Joint Letter to the SEC on proposed changes to Rule 14a-8
July 28, 2020 CII letter to DOL on Financial Factors in Selecting Plan Investments
July 20, 2020 CII letter to SEC on good faith determination of fair value proposal 
July 16, 2020 CII letter to SEC on NYSE direct listing proposal
July 8, 2020 CII letter to SEC on Roundtable on Emerging Markets
July 6, 2020 Joint letter to SEC on virtual and hybrid meetings
June 29, 2020 CII letter to SEC on PCAOB board seat
June 25, 2020 CII letter to SEC on Nasdaq proposed rules regarding companies from restrictive markets
June 18, 2020 CII letter to SEC on Nasdaq proposed rule regarding listed company’s auditor in a restrictive market
June 11, 2020 CII letter to PCAOB on Interim Analysis No. 2020-01, Critical Audit Matter Requirements
June 11, 2020 CII responses to European Commission consultation on Non-Financial Reporting Directive review 
June 5, 2020 Joint CII ILPA Letter to SEC on IA Committee 
May 28, 2020 CII letter to SEC on exempt offering framework
May 21, 2020 CII letter to World Economic Forum regarding sustainability dislcosure consultation
May 19, 2020 CII supplemental comment letter on SEC proposed amendments to Rule 14a-8
May 14, 2020 CII letter to S&P regarding Facebook and S&P 500 ESG Index
May 5, 2020 CII letter to SEC on fund names
May 3, 2020 CII letter to the SEC Investor Advisory Committee on public company disclosure considerations and shareholder engagement/virtual shareholder meetings in the Covid-19 pandemic context
April 29, 2020 CII and CFA Institute joint comment letter to SEC on MD&A proposal
April 27, 2020 CII and CFA joint letter to Congressional Leadership supporting independent accounting standard setting
April 23, 2020 CII letter to SEC on IEX D-Limit order type
April 23, 2020 PCAOB response letter to April 9 CII letter on Luckin Coffee
April 23, 2020 CII response to HKEX corporate dual-class consultation
April 22, 2020 Letter from CII and other investor groups to AT&T on participation in virtual shareholder meeting
April 16, 2020 CII comment letter to SEC on NYSE direct listing proposal
April 9, 2020 CII letter to PCAOB Chairman on Luckin Coffee Inc.
March 27, 2020 Reactions from Legal Experts to Footnote # 169 in Salzberg v. Blue Apron Holdings, Inc., et al.
March 19, 2020 CII comment letter to PCAOB on Quality Control Standards
March 16, 2020 CII comment letter to SEC on Qualifications of Accountants
March 12, 2020 CII response to Hang Seng dual class consultation
Feb. 27, 2020 Remarks to SEC IAC on Initial Reporting of CAMs
Feb. 20, 2020 CII comment letter to the SEC on amendments to exemptions from the proxy rules for proxy voting advice
Feb. 20, 2020 CII comment letter to the SEC on proposed order regarding the National Market System plans
Feb. 13, 2020 CII and investor letter to the SEC on pragmatic problems with proposed proxy advisor regulation
Feb. 13, 2020 CII supplemental comment letter on SEC proposal to regulate proxy advisors, posing questions about on the economic analysis
Feb. 11, 2020 Comment letter to SEC supporting IEX proposal for new discretionary limit order type
Feb. 11, 2020 Comment letter on SEC’s proposed amendments to Investment Advisor Advertisements Rule
Feb. 4, 2020 CII supplemental comment letter on SEC proposal to regulate proxy advisors, concerning allegations of proxy advisor errors
Jan. 30, 2020 Comment letter to the SEC on proposed rules for proxy voting advice
Jan. 30, 2020 Comment letter to the SEC on proposed amendments to Rule 14a-8
Jan. 28, 2020 CII appeal to SEC regrading FOIA determination (Response: Notice of Remand on Apr. 29, 2020)
Jan. 16, 2020 CII letter to SEC on NYSE proposed direct listings rule
Jan. 9, 2020 Letter Thanking Intuit’s Board on Opposing Mandatory Arbitration Shareholder Proposal
Dec. 31, 2019 Letter to SEC GC seeking dispute resolution on FOIA request for SEC analysis of errors by proxy advisors
Dec. 5, 2019 Letter to SEC on NMS Plan Fee Amendments
Dec. 2, 2019 Letter to Speaker and Republican Leader on Insider Trading Prohibition Act
Nov. 26, 2019 Letter to SEC on PCAOB auditor independence guidance
Nov. 25, 2019 Letter to House Financial Services Committee leaders on PE fund hearing
Nov. 22, 2019 Letter to SEC with additional organizations supporting 120-day comment period on proposed rules
Nov. 15, 2019 Letter to SEC requesting 120-day comment periods on proxy advisor and 14a-8 proposals
Nov. 14, 2019 Letter to SEC requesting more information on proxy advisor proposal
Nov. 14, 2019 CII FOIA request for SEC analysis of alleged proxy advisor errors    Response letter
Nov. 4, 2019 CII & CFA joint letter to UK Department for Business, Energy and Industrial Strategy on internal controls
Oct. 28, 2019 CII amicus brief in Salzberg v. Sciabacucchi to the Delaware Supreme Court regarding forum selection provisions
Oct. 24, 2019 CII comment letter to SEC on proxy advisor regulation
Oct. 23, 2019 CII letter to Chair and Ranking Member of Subcommittee on Investor Protection, Entrepreneurship, and Capital Markets regarding hearing on “Examining Corporate Priorities: The Impact of Stock Buybacks on Workers, Communities, and Investors”
Oct. 17, 2019 CII letter to SEC on proposal to modernize Regulation S-K
Oct. 15, 2019 CII letter to SEC on proxy advisor regulation co-signed by 60 investors and investor organizations
Oct. 9, 2019 CII letter to SEC on PCAOB appointments
Oct. 3, 2019 CII letter to SEC on Concept Release on Harmonization of Securities Offering Exemptions
Sept. 20, 2019 CII letter to Airbnb on equity structure as a public company
Sept. 19, 2019 Joint letter to the SEC on new no-action policy
Sept. 17, 2019 Joint Petition to the SEC for Transparency of Funding of Consolidated Market Data
Sept. 13, 2019 CII letter to Delaware State Bar Association to amend DGCL to limit dual class stock companies (DGCL Response)
Sept. 13, 2019 CII letter to ABA to amend the MBCA to limit dual class stock companies
 ABA Response
Sept. 4, 2019 CII letter to Peloton on equity structure as a public company
Aug. 22, 2019 CII letter to SEC/CFTC on customer margin rules
Aug. 15, 2019 CII letter to SEC on proxy voting and proxy advisors
Aug. 12, 2019 CII letter to SEC on 14a-8 process
Aug. 2, 2019 CII letter to The We Company on equity structure as a public company
Aug. 1, 2019 CII letter to SEC on LTSE proposed rule change to adopt rule 14.425
Aug. 1, 2019 Joint CII and Investment Company Institute amicus brief in support of denying stock exchange petitions for review of the SEC's transaction fee pilot
July 29, 2019 CII Letter to SEC on proposed amendments to financial disclosures about acquired and disposed businesses
July 25, 2019 CII comment letter to the SEC on the proposed amendment related to SOX 404(b)
July 18, 2019 CII comment letter to the SEC on the Regulatory Flexibility Agenda
Attachment: FedEx 2019 Proxy Appendix C: Reconciliations of Non-GAAP Measures
July 10, 2019 CII letter to Chair and Ranking Member of Committee on Financial Services Regarding Markup of the “Improving Corporate Governance through Diversity Act of 2019” and the “Diversity in Corporate Leadership Act of 2019”
July 9, 2019 CII letter to Chair and Ranking Member of Subcommittee on Investor Protection, Entrepreneurship, and Capital Markets regarding hearing on “Building a Sustainable and Competitive Economy: An Examination of Proposals to Improve Environmental, Social and Governance Disclosures”
June 27, 2019 CII letter to Senators Grassley & Reed regarding S. 1256. 
June 26, 2019 CII letter to Endeavor Group on its dual-class IPO
June 26, 2019 CII-CFA-HMA joint letter to SEC Chairman Jay Clayton on MiFID II 
June 20, 2019 CII letter to SEC Division of Corporation Finance on interpretation of the 14a-8(i)(7) ordinary business exclusion in no-action letters
June 19, 2019 CII letter to Chair & Ranking Member of Committee on Financial Services regarding hearing on Diversity in the Boardroom: Examining Proposals to Increase the Diversity of America’s Boards
June 18, 2019 CII letter to Chair and Ranking Member of Subcommittee on Investor Protection, Entrepreneurship, and Capital Markets of Committee on Financial Services regarding hearing on “Putting Investors First: Examining Proposals to Strengthen Enforcement Against Securities Law Violators”
May 21, 2019 CII letter to CrowdStrike on its multi-class IPO
May 14, 2019 CII letter to Chair & Ranking Member of Subcommittee on Investor Protection, Entrepreneurship, & Capital Markets regarding hearing on “Promoting Economic Growth: A Review of Proposals to Strengthen the Rights and Protections for Workers”
May 7, 2019 CII letter to Chair & Ranking Member of the Committee on Financial Services regarding markup of Insider Trading Prohibition Act of 2019
May 2, 2019 CII letter to SEC on NASDAQ Regulation A proposal
April 29, 2019 CII petition to the SEC on non-GAAP financials in proxy statement CD&As
April 18, 2019 CII letter to SEC regarding PCAOB standards on estimates and specialists
April 9, 2019 CII letter to Chair and Ranking Member of Subcommittee on Investor Protection, Entrepreneurship, and Capital Markets regarding hearing on “Putting Investors First: Reviewing Proposals to Hold Executives Accountable”   
April 8, 2019 CII letter to Chairman and Ranking Member of Senate Banking Committee regarding hearing on application of ESG principles in investing
April 4, 2019 CII letter to Duke Energy on shareholder meeting access - Duke response
March 28, 2019 CII Executive Director Ken Bertsch's testimony in front of the SEC's Investor Advisory Committe
March 26, 2019 CII letter to Pinterest on its multi-class IPO
March 21, 2019 CII letter to SEC on earnings releases and quarterly reports
March 13, 2019 CII letter to SEC on NASDAQ direct listing proposal
March 11, 2019 CII letter to Levi Strauss on its multi-class IPO
Feb. 27, 2019 CII letter to Chair and Ranking Member of Senate Banking Committee regarding hearing on capital formation and corporate governance
Feb. 15, 2019 CII letter to SEC on stock exchange costs
Feb. 13, 2019 CII letter to Lyft on its multi-class IPO
Feb. 11, 2019 CII letter to SEC on NYSE SPACs proposal
Feb. 6, 2019 CII letter to Representative Meeks on Improving Corporate Governance Through Diversity Act
Jan. 31, 2019 CII letter to SEC on proxy mechanics
Jan. 31, 2019 CII letter to SEC on MiFID II research provisions
Jan. 31, 2019 CII letter to SEC on mandatory arbitration
Jan. 22, 2019 CII letter to SEC on Long-Term Stock Exchange, Inc's registration as a national securities exchange
Jan. 22, 2019 CII letter to Chair and Ranking Member of Committee on Financial Services regarding H.R. 624
Dec. 20, 2018 CII letter to SEC on improving retail shareholder voting turnout and XBRL
Dec. 13, 2018 CII letter to SEC on reg. flex agenda
Dec. 6, 2018 CII letter to FTC on common ownership
Dec. 5, 2018 CII letter to Senate Banking Commitee on proxy process and rules
Nov. 26, 2018 CII letter to SEC on Reg. S-X disclosures about guarantors
Nov. 8, 2018 CII letter to SEC on the proxy system
Nov. 8, 2018 CII letter to SEC on security-based swap proposals
Nov. 8, 2018 CII letter to SEC on NYSE SPACs proposal
Nov. 8, 2018 CII letter to Qualtrics International on its multi-class IPO
Oct. 24, 2018 CII letter to NASDAQ on sunset provisions
Oct. 24, 2018 CII letter to NYSE on sunset provisions
Sept. 13, 2018 Executive Director Ken Bertsch's Remarks to the SEC Investor Advisory Committee on U.S. Proxy Voting Infrastructure
Sept. 11, 2018 CII letter to Zekelman Industries on its multi-class IPO
Sept. 6, 2018 CII letter to the PCAOB on the 2018-2022 draft strategic plan
Aug. 24, 2018 CII letter to Eventbrite encouraging a sunset of seven years or less
Aug. 14, 2018 Joint CII-MFA comment letter in support of de minimis exemption and clarification of investment-only exemption
July 26, 2018 CII letter to ASX on "Review of the ASX Corporate Governance Council’s Principles and Recommendations"
July 20, 2018 CII letters to public companies on SEC transaction fee pilot
Sent to ACCO Brands, Ampco-Pittsburgh Corp., Anixter International, Apache Corp., BancorpSouth, Bank of Hawaii Corp., Cboe Global Markets, Cott Corp., Energizer Holdings, Ennis Inc., Era Group, Ethan Allen Global, Federal Agricultural Mortgage Corp., First Majestic Silver Corp., Genesis Healthcare, Halliburton, Haverty Furniture Companies, Home Depot, Johnson Controls International, Knight-Swift Transportation Holdings, Leaf Group, Level Brands, Mastercard, McDermott International, Mexco Energy, Natural Grocers, Newpark Resources, NorthWestern Energy, ProAssurance Corp., Procter & Gamble, Sensient Technologies, SIFCO Industries, Standard Motor Products, Tredegar, Trex Company, Unitil Corp., and Weingarten Realty
July 19, 2018 CII letter to SEC on strategic plan
July 12, 2018 CII response to European Commission consultation on effectiveness of EU public reporting framework
July 11, 2018 CII letter to SEC on semi-annual regulatory agenda
July 10, 2018 CII letter to Chair and Ranking Member of House Financial Services Committee on markup of legislative proposals regarding 10b5-1 plans and multi-class stock disclosures
July 5, 2018 CII letter to Netflix on corporate governance concerns
June 28, 2018 CII letter to SEC regarding auditor independence
June 27, 2018 CII letter to Chair and Ranking Member of Senate Banking Committee on H.R. 4015 and S. 536
June 25, 2018 CII letter to Domo on its dual-class IPO
June 12, 2018 CII letter to Chair and Ranking Member of House Capital Markets Subcommittee regarding H.R. 5037
June 6, 2018 CII letter to Chair and Ranking Member of House Financial Services Committee on markup of legislative proposals
June 1, 2018 CII letters to Maryland-incorporated REITs on ownership threshold requirements to propose bylaw amendments Sent to AvalonBay Communities, CoreCivic, Digital Realty Trust, Douglas Emmett, Equity Lifestyle Properties, Equity Residential, Essex, Franklin Street Properties, Healthcare Trust of America, Macerich, PennyMac Mortgage Investment Trust, and Realty Income Corporation
May 31, 2018 CII response to UK Department for Business, Energy & Industrial Strategy consultation "Insolvency and Corporate Governance"
May 22, 2018 CII letter to Chair and Ranking Member of House Capital Markets Subcommittee on legislative proposals
May 14, 2018 CII letter to GreenSky on its Up-C IPO with unequal voting rights
May 14, 2018 CII letter to Pluralsight on its Up-C IPO with unequal voting rights
May 10, 2018 CII letter to SEC on transaction fee pilot
May 10, 2018 CII letter to SandRidge Energy on universal proxy
May 9, 2018 CII letter to MSCI on treatment of unequal voting structures
May 8, 2018 CII letter to SEC on oversight of cryptocurrencies and initial coin offerings
April 26, 2018 CII letter to Singapore Exchange on dual-class consultation
April 18, 2018 CII letter to Pivotal Software on its dual-class IPO
April 18, 2018 CII letter to Vrio on its dual-class IPO
March 26, 2018 CII letter to SEC on NYSE listing standard for SPACs
March 22, 2018 CII letter to Hong Kong Stock Exchange on the consultation paper A Listing Regime for Companies From Emerging and Innovative Sectors
March 15, 2018 CII letter to Corporate Governance Council of Singapore
March 5, 2018 Joint CII, Ceres, ICCR, and US SIF letter regarding S. 2155 and Rule 14a-8
Feb. 28, 2018 CII response to Proposed Revisions to UK Corporate Governance Code
Feb. 27, 2018 Co-signed letter to the Senate Banking Committee on proposed legislation relating to proxy advisory firms and institutional investors (H.R. 4015)
Feb. 27, 2018 CII response to IESBA Fees Questionnaire
Feb. 26, 2018 CII letter to Dropbox on multi-class share structure
Feb. 23, 2018 Letter to the editor in The Wall Street Journal: Don’t Forget the Good That SOX Has Done
Feb. 22, 2018 CII letter to Capitol One on special meeting proposal
Feb. 22, 2018 CII letter to SEC on NYSE direct listing proposal
Feb. 12, 2018 CII letter on SEC chair's rulemaking priorities (RegFlex Agenda)
Feb. 8, 2018 CII letter in response to Monitoring Group Consultation
Jan. 31, 2018 CII letter to SEC on no-action relief at AES Corporation
Jan. 29, 2018 CII letter to SEC on forced arbitration provisions in public company governing documents
Jan. 25, 2018 CII follow-up letter to SEC on NASDAQ listing standard for SPACs
Jan. 18, 2018 CII follow-up letter to the SEC on potential misuse of Rule 10b5-1 trading plans
Dec. 20, 2017 CII letter to SEC on NYSE listing standard for SPACs
Dec. 20, 2017 CII letter to SEC on FAST Act proposal
Dec. 14, 2017 CII responses to BPP consultation questionnaire
Dec. 12, 2017 CII letter to Speaker and Minority Leader on proxy advisory firm legislation
Attachment:  November 9, 2017 letter from CII and 45 investor and investor organizations on proxy advisory firm legislation 
Dec. 8, 2017 CII letter to Hong Kong Exchange regarding consultation on corporate governance
Dec. 7, 2017 Joint CII and ILPA Letter to Conferees on Tax Cuts & Jobs Act
Nov. 22, 2017 CII letter to Chair and Ranking Member of the Senate Finance Committee on the Unrelated Business Income Tax and Public Pension Plans
Nov. 16, 2017 CII letter to Federal Reserve on boards of directors
Nov. 13, 2017 CII response to ISS 2018 Benchmark Survey
Nov. 9, 2017 Joint letter from CII, Ceres, ICCR, and US SIF regarding rule 14a-8
Attachment: An Investor Response to the U.S. Chamber's Proposal to Revise SEC Rule 14a-8
Nov. 9, 2017 CII joint letter to House Financial Services Committee on H.R. 4015 on legislation relating to proxy advisory firms
Oct. 25, 2017 CII letter to SEC on NASDAQ listing standard for SPACs
Oct. 19, 2017 California State Teachers’ Retirement System v. Alvarez amicus curiae brief
Oct. 18, 2017 CII letter to MongoDB on its dual-class IPO
Oct. 12, 2017 CII letter to FCA on proposed changes to premium listing requirements for sovereign controlled companies
Oct. 10, 2017 CII letter to SEC on human capital management disclosures
Oct. 6, 2017 CII letter to Switch Inc. on dynastic multi-class IPO
Sept. 22, 2017 CII letter to SEC on no-action relief relating to MiFID II
Sept. 13, 2017 CII letter to Roku on its dual-class IPO
Sept. 7, 2017 CII letter to SEC on regulatory agenda 
Aug. 28, 2017 CII letter to PCAOB on estimates and specialist proposals
Aug. 23, 2017 CII letter to Treasury on Capital Markets Report
Aug. 21, 2017 CII letter to SEC regarding rule 14a-8
Aug. 8, 2017 CII letter to SEC regarding new PCAOB auditor reporting standard
Aug. 4, 2017 CII letter to Hong Kong Exchange on New Board concept paper
Aug. 3, 2017 CII letter to MSCI responding to consultation on the treatment of non-voting shares
July 28, 2017 CII letter to Netflix on corporate governance concerns
July 20, 2017 CII letter to Speaker and Minority Leader regarding universal proxy rider
July 17, 2017 CII letter to House Subcommittee on Capital Markets, Securities, and Investment on Hearing on Cost of Being a Public Company
July 10, 2017 CII letter to Chair and Ranking Member of the House Appropriations Committee on universal proxy rider
July 7, 2017 CII letter to Senator Reed on the Cybersecurity Disclosure Act (S.536)
July 5, 2017 Joint letter from CII, Ceres, Interfaith Center on Corporate Responsibility, and US SIF requesting a meeting with SEC Chair to discuss Rule 14a-8
June 26, 2017 CII letter to Nasdaq on voting rights on private placements
June 20, 2017 CII letter to Blue Apron about its triple-class structure
June 19, 2017 CII letter to Canadian government on majority voting and annual elections
June 14, 2017 CII letter to FTSE Russell on voting rights consultation
June 8, 2017 CII letter to Broadridge Committee on virtual shareholder meeting technology
June 5, 2017 Email to House Speaker Ryan regarding Joint Statement on Defending Fundamental Shareholder Rights
Similar emails were sent to all members of the House of Representatives
May 17, 2017 Co-signed letter to Speaker of the House of Representatives Paul Ryan
Similar letters were sent to all members of the House of Representatives
May 1, 2017 Joint CII, Center for Audit Quality and CFA Institute letter to House Financial Services Committee on the Financial CHOICE Act
April 29, 2017 CII letter to House Financial Services Committee on mark-up of the Financial CHOICE Act
April 28, 2017 Testimony of Ken Bertsch before the Committee on Financial Services
April 27, 2017 CII submission to S&P Dow Jones on no-vote shares
April 24, 2017 CII letter to House Financial Services Committee on the CHOICE Act discussion draft
April 11, 2017 CII letter to XPO on exclusive forum bylaw
April 6, 2017 CII letter to Senate Banking Committee in response to request for proposals to foster economic growth
April 4, 2017 CII letter to IFRS Advisory Council Chair on updated CII policy
Attachment: Independence of Accounting and Auditing Standard Setters
March 29, 2017 CII letter to Duke Energy on virtual-only shareholder meeting (response) Similar letters sent to to Ford, ConocoPhillips (response), GEO Group, Union Pacific (response), IDEXX Laboratories (response), Pinnacle West Capital
March 29, 2017 CII letter to Singapore Stock Exchange on one share, one vote
March 29, 2017 CII letter to MSCI requesting consultation on exclusion of no-vote shares
March 24, 2017 CII letter to FTSE/Russell requesting consultation on exclusion of no-vote shares
March 23, 2017 Proposed questions for the confirmation hearing of SEC Chair Nominee Jay Clayton
March 15, 2017 Joint letter to National Economic Council on shareholder proposal process
March 13, 2017 CII letter to House Financial Services Committee members on JOBS Act hearing
March 9, 2017 Testimony before the SEC Investor Advisory Committee: Unequal Voting Rights in Common Stock
March 9, 2017 CII letter to house speaker and minority leader opposing H.R. 985
Feb. 22, 2017 Written Testimony to the Economic Matters Committee, Maryland House of Delegates, on HB 0589: "Corporate Bylaws and Election of Directors and Trustees"
Feb. 9, 2017 CII letter to to the Department for Business, Energy & Industrial Strategy of the U.K. Government in response to its Corporate Governance Reform Green Paper
Feb. 9, 2017 CII letter to House Financial Services Committee Chair on the Financial CHOICE Act and funding for the Governmental Accounting Standards Board
Feb. 3, 2017 CII letter to Snap on proposed multi-class post-IPO structure
Related: February 21 Snap response letter to CII
Jan. 12, 2017 CII letter to House Leadership on H.R. 78.
Dec. 28, 2016 CII comment letter to SEC on universal proxy
Dec. 8, 2016 CII Executive Director Ken Bertsch - Remarks to SEC Investor Advisory Committee
Nov. 10, 2016 CII letter to ISS on multi-class sunset provisions 
Nov. 10, 2016 CII letter to Congressional Leadership opposing riders
Oct. 26, 2016 CII letter to SEC on Subpart 400 of Regulation S-K
Oct. 18, 2016 CII letter to SEC on Exhibit Hyperlinks
Sept. 22, 2016 CII letter to SEC on 'Disclosure Update and Simplification' proposal
Sept. 20, 2016 CII letter to Capital Markets Subcommittee on corporate governance hearing
Sept. 12, 2016 CII letter to Chair and Ranking Member of the Committee on Financial Services regarding the CHOICE Act of 2016
Sept. 7, 2016 CII letter to Speaker of House and Minority Leader opposing H.R. 5424
See also: similar letters from CalSTRS and Americans for Financial Reform
Sept. 6, 2016 Co-signed CII letter to Senate Banking Committee on proposed legislation relating to proxy advisory firms
Aug. 30, 2016 CII/CAQ letter to SEC on Smaller Reporting Company Definitions
July 27, 2016 CII letter to PCAOB on proposed amendments to Audit Report Standards
July 15, 2016 CII letter to six agencies on incentive-based pay at certain financial institutions
July 8, 2016 CII letter to SEC on Regulation S-K Concept Release 
June 13, 2016 CII letter to the House Financial Services Committee on the Corporate Governance Reform and Transparency Act of 2016 (HR 5311)
June 13, 2016 CII letter to the House Financial Services Committee on the SEC Regulatory Accountability Act (H.R. 5429)
May 17, 2016 Legislative Proposals to Enhance Capital Formation, Transparency, and Regulatory Accountability - Statement of Ken Bertsch for the Subcommittee on Capital Markets and Government Sponsored Enterprises of the Committee on Financial Services
April 27, 2016 CII comment letter to Department of Justice on investor-company dialogue
April 14, 2016 CII comment letter to SEC on end-to-end vote confirmation
Feb. 23, 2016 CII comment letter to SEC on NASDAQ proposal on director pay transparency
Feb. 10, 2016 CII comment letter to Nasdaq on concept release on shareholder approval for certain stock issuances
Dec. 3, 2015 CII letter to FASB on proposed changes to financial reporting
Nov. 16, 2015 Statement of Amy Borrus for the Corporate Governance Roundtable hosted by Rep. Scott Garrett, United States House of Representatives: Panel 2: Examining the U.S. Proxy System: Is it Working for Everyone?
Nov. 5, 2015 CII letter to SEC on proxy-related matters
Sept. 17, 2015 CII letter to PCAOB on the board's Concept Release on Audit Quality
Sept. 14, 2015 CII letter to SEC on funding
Aug. 27, 2015 CII comment letter to SEC on clawbacks
Aug. 19, 2015 CII comment letter to SEC on audit committee disclosures
July 30, 2015 CII comment letter to PCAOB on disclosure of audit participants
July 1, 2015 CII letter to SEC on proxy related issues
June 25, 2015 CII letter to SEC on 953(a)
June 12, 2015 CII letter to SEC on voting requirement disclosure and certain other disclosures
May 26, 2015 CII letter to SEC on disclosure of preliminary vote tallies
May 6, 2015 CII letter to Delaware State Senators urging passage of SB 75 to eliminate fee-shifting bylaws
May 5, 2015 CII letter to New York State Assembly on remote shareholder meeting attendance
April 16, 2015 CII letter to SEC on hedging
March 25, 2015 CII letter to SEC on Scope and Application of Rule 14a-8 (i) (9)
March 5, 2015 CII letter to SEC on universal proxy
Feb. 5, 2015 CII letter to EU Parliament supporting "one share, one vote"
Jan. 30, 2015 CII letter to Japan’s Financial Services Agency on Draft Corporate Governance Code
Attachment: CII Corporate Governance Policies
Jan. 29, 2015 CII letter to ISS and Glass Lewis on proxy access
Jan. 13, 2015 CII letters on proxy access to Chipotle Mexican Grill, Anadarko Petroleum, Apache, Arch Coal, Cabot Oil & Gas, CF Industries, Cimarex Energy, Citigroup, Cloud Peak Energy, Community Health Systems, ConocoPhillips, Domino’s Pizza, eBay, Exelon, Expeditors International, FirstEnergy, FirstMerit, Kohl's, Marathon Oil, Noble Energy, SBA Communications and YUM! Brands
Jan. 10, 2015 CII letter to OECD on Principles of Corporate Governance 
Attachment: CII Corporate Governance Policies
Jan. 9, 2015 CII letter to SEC on proxy access at Whole Foods
Jan. 8, 2015 CII letter to Whole Foods on proxy access
Dec, 5, 2014 CII letter to the Washington Post on Fee-Shifting Bylaws
Dec. 5, 2014 CII letter to Prime Minister of Japan on proposed corporate governance code
Attachment: CII Corporate Governance Policies
Nov. 25, 2014 CII letter to Delaware Bar Chair of Section of Corporation Law on fee-shifting provisions
Nov. 18, 2014 CII letter submitted to the Wall Street Journal regarding Delaware shareholder lawsuits
Nov. 13, 2014 CII letter to prudential regulators on re-proposed rules for uncleared swap margin
Oct. 2, 2014 Jeff Mahoney's remarks to PCAOB Standing Advisory Group
Aug. 21, 2014
Aug. 15, 2014 CII letter to PCAOB on Imposing Transparency of Audits
Aug. 6, 2014 CII letter to SEC on pay for performance provision of Dodd-Frank
Aug. 1, 2014 CII letter to European Parliament on shareholder rights directive
July 23, 2014 CII Letter to Subcommittee on Capital Markets re SEC hearing
July 15, 2014 CII letter to Speaker Boehner and Minority Leader Pelosi opposing H.R. 5016 the Financial Services and General Government Appropriations Act of 2015
July 9, 2014 CII letter to Prime Minister of Japan on proposed corporate governance code (English)
Attachment: CII corporate governance policies
July 9, 2014 CII letter to Prime Minister of Japan on proposed corporate governance code (Japanese translation)
Attachment: CII corporate governance policies
July 8, 2014 CII letter to SEC on Committee on Capital Markets Regulation recommendation regarding zombie directors
July 3, 2014 CII letter to Seventh Circuit enclosing amicus curiae brief 
CII amicus curiae brief in the Corre Opportunities Fund, et al. v. Emmis Corp. 
June 25, 2014 SEC response to CII's May 22 letter on proxy distributors, universal proxy cards and director compensation
June 13, 2014 CII letter to Senator Townsend supporting DE bill barring fee-shifting bylaws
June 11, 2014 CII letter to the Financial Reporting Council on proposed revisions to the U.K. Corporate Governance Code
May 22, 2014 CII letter to the SEC on proxy distributors, universal proxy cards and director compensation
May 22, 2014 CII letter to Japanese Legislature in support of corporate governance reforms
May 22, 2014 CII letter to Japanese Prime Minister in support of corporate governance reforms
May 6, 2014 Joint CII, CAQ letter to the House Financial Services Committee on HR 2629
April 30, 2014 CII letter to Congress on proposed bills to amend JOBS Act
April 10, 2014 CII letter to the PCAOB on auditor’s reporting model
Attachment
March 31, 2014 CII letter to SEC on director pay transparency
March 27, 2014 CII letter to NYSE on one share, one vote
March 27, 2014 CII letter to NASDAQ on one share, one vote
March 27, 2014 CII letter to the London Stock Exchange on one share, one vote
March 27, 2014 CII letter to the Hong Kong Exchange on one share, one vote
March 26, 2014 CII letter to SEC on asset-backed securities
March 19, 2014 CII letter to NASDAQ on majority voting listing standard
March 19, 2014 CII letter to NYSE on majority voting listing standard
March 17, 2014 CII letter to PCAOB: Improving the transparency of audits
March 11, 2014 CII letter to SEC on Draft Strategic Plan
March 6, 2014 CII letter to SEC on proxy distributors
Feb. 24, 2014 CII letter to Industry Canada regarding its Consultation on the Canada Business Corporations Act
Feb. 11, 2014 CII letter to the Office of the Comptroller of the Currency on proposed national banking rules
Jan. 8, 2014 CII letter to IAASB on International Standards on Auditing 
Attachment: Dec. 16, 2013 Letter to PCAOB on Proposed Auditing Standards
Attachment: Dec. 16, 2013 Responses to Select Questions
Jan. 8, 2014 CII letter to SEC on universal proxy cards
Dec. 16, 2013 CII letter to PCAOB on Rulemaking Docket Matter 034, entitled, "Proposed Auditing Standards"
Attachment: CII Responses to Select Questions
Dec. 12, 2013 CII letter to Senate Judiciary Committee on forced arbitration clauses in corporate bylaws
Dec. 11, 2013 CII letter to SEC regarding forced arbitration clauses in corporate bylaws
Dec. 3, 2013 CII comment letter to House leadership on The Small Business Capital Access and Job Preservation Act
Nov. 21, 2013 CII letter to Canadian Securities Administrators on consultation paper regarding proxy voting infrastructure
Nov. 6, 2013 CII letter to SEC on the proposed rule to implement section 953(b) of the Dodd-Frank Act
Attachment: Proposed Rule to Implement Section 953(b) of the Dodd-Frank Act
Aug. 16, 2013 CII letter to SEC regarding pay versus performance
Aug. 2, 2013 CII Advisory Council members' letter to NYSE on majority voting for directors
Aug. 2, 2013 CII Advisory Council members' letter to NASDAQ on majority voting for directors
Aug. 1, 2013 CII letter to Nabors Industries about voting procedures
July 11, 2013 CII letter to the Canadian Securities Administrators on proposal to enact significant changes to its early warning reporting system
June 26, 2013 CII letter to Senate Banking Committee on nomination hearing for new SEC commissioners
Attachment - issues for nominees to be a member of the SEC
June 20, 2013 CII letter to NYSE on requiring directors to be elected by majority vote
Attachment - proposed listing standards
June 20, 2013 CII letter to Nasdaq on requiring directors to be elected by majority vote
Attachment - proposed listing standards
June 13, 2013 CII letter to SEC on proxy advisory firms
June 5, 2013 Statement of Ann Yerger to House Financial Services Subcommittee on Capital Markets and Government Sponsored Enterprises: Examining the Market Power and Impact of Proxy Advisory Firms
May 23, 2013 CII letter to PCAOB on adding audit partner name to auditor's report
May 17, 2013 CII letter to SEC regarding proxy distributors
May 15, 2013 CII letter to House leadership opposing cost-benefit requirements on SEC rulemaking
May 9, 2013 CII follow-up letter to the SEC on potential misuse of Rule 10b5-1 trading plans
May 1, 2013 CII letter to Senate Committee on Agriculture, Nutrition & Forestry on CFTC enforcement of central clearing and trading requirements of Dodd-Frank and CFTC funding
April 26, 2013 CII follow-up letter to SEC supporting unbundling management proposals on the proxy
April 22, 2013 CII letter to Mass SJC on the timing of shareowner meetings
April 5, 2013 CII letter to SEC about NYSE proposed rule relating to success fee for enhanced brokers’ internet platforms
March 26, 2013 Delaware bar association response to CII's October 25, 2012, letter on majority voting
March 26, 2013 SEC response letter to the March 13 letter on unbundling proxy proposals
March 13, 2013 CII letter to SEC supporting unbundling management proposals on the proxy
March 11, 2013 CII letter to Senate Banking on nomination of Mary Jo White to chair SEC
Attachment: candidate questions
Jan. 7, 2013 CII letter to NYSE on Simon Property Group stock incentive plan
Dec. 28, 2012 CII letter to SEC on potential misuse of Rule 10b5-1 trading plans for executive sales of company stock
Dec. 10, 2012 CII follow-up letter to NYSE meeting on dual-class stock
Nov. 5, 2012 CII letter to Toronto Stock Exchange on proposed listing requirement for majority voting for directors
Attachments:
CII letter to ABA on majority voting for directors
Proposed amendments to Model Business Corporation Act
CII letter to Delaware bar association on majority voting for directors
Proposed amendments to Delaware General Corporation Law
Nov. 1, 2012 CII letter to SEC on NYSE proposed listing standards for compensation committees
Attachment: CII corporate governance policy on independent directors
Nov. 1, 2012 CII letter to SEC on Nasdaq proposed listing standards for compensation committees
Attachment: CII corporate governance policy on independent directors
Oct. 31, 2012 Response letter from Delaware bar association on majority voting for directors
Oct. 25, 2012 CII letter to ABA on majority voting for directors
Attachment: Proposed amendments to Model Business Corporation Act
Oct. 25, 2012 CII letter to Delaware bar association on majority voting for directors
Attachment: Proposed amendments to Delaware General Corporation Law
Oct. 2, 2012 CII letter to NYSE urging end to new listings of dual-class stock companies
Oct. 2, 2012 CII letter to Nasdaq urging end to new listings of dual-class stock companies
Sept. 27, 2012 CII comment letter to SEC in response to proposed JOBS Act rule on general solicitation
Sept. 21, 2012 CII letter to Committee on Homeland Security and Governmental Affairs on the Independent Agency Regulatory Analysis Act
Sept. 20, 2012 CII letter to IAASB on auditor reporting
Aug. 16, 2012 CII letter to SEC on Section 201(a) of the JOBS Act
Aug. 10, 2012 CII letter to 18 banks regarding Libor integrity (example: Barclays)
Recipients included all Libor-reporting banks. Click on any linked bank's name to view their response:
Bank of America, Barclays, BNP Paribas, Citibank, Credit Agricole, Credit Suisse, Deutsche Bank, HSBC, JPMorgan Chase, Lloyds Banking Group, Norinchukin Bank, Rabobank, Royal Bank of Canada, Royal Bank of Scotland, Societe Generale, Sumitomo Mitsui, Tokyo-Mitsubishi UFJ, UBS
Aug. 9, 2012 CII letter in response to SEC's request for public comments on Title I of the JOBS Act
July 31, 2012 Joint letter from CII and CAQ opposing H.R. 6161
July 23, 2012 CII letter to SEC in support of Dodd-Frank Act
July 20, 2012 CII letter to Senate Banking Committee, House Financial Services Committee, Treasury, SEC, White House and FINRA on CII's JOBS Act issue briefs
Attachment: See JOBS Act Issue Briefs page
May 10, 2012 CII letter to PCAOB on unusual transactions
March 22, 2012 Joint letter from CII and Center for Audit Quality to Senate on the JOBS Act
March 8, 2012 CII letter to House Appropriations Committee on SEC funding
March 7, 2012 CII letter to House leadership on capital formation
March 1, 2012 CII letter to Senate Banking Committee on capital formation
Feb. 3, 2012 CII letter to Banking Committee regarding Morrison white paper
Attachment: Morrison v. National Australia Bank: The Impact on Institutional Investors
Feb. 3, 2012 CII letter to Financial Services Committee regarding Morrison white paper
Attachment: Morrison v. National Australia Bank: The Impact on Institutional Investors
Jan. 23, 2012 Delaware bar association second response to CII Aug. 11, 2011, letter on majority voting for directors
Jan. 5, 2012 CII letter to PCAOB on audit transparency


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