We share the Commission’s concerns about concentration in the proxy advisory market. Yet, we disagree with the following proposed remedies: 1) forcing proxy advisors to share their opinions with managers ahead of time and 2) treating opinions on proxies as proxy solicitations. By increasing the cost of opining on proxy statements such proposals will only discourage new entry into the proxy advisory market and exacerbate the problem of market concentration in this sector.
SECによる規則提案に対するパブリック・コメントです。会社法研究者だけでなく、経済学者も名を連ねています。
See also Amendments to Exemptions from the Proxy Rules for Proxy Voting Advice