Yearly Archives: 2017

Roadblocks to Redemption: Delaware Chancery Court Makes Preferred Stock Redemptions More Challenging

Michael J. Kendall is a partner and Joseph F. Bernardi, Jr. is counsel at Goodwin Procter LLP. This post is based on a Goodwin Procter publication by Mr. Kendall and Mr. Bernardi, and is part of the Delaware law series; links to other posts in the series are available here.

A recent decision in Delaware illustrates yet another difficulty investors face when using redemption of their stock as a liquidity strategy. In this case, a private equity fund, Oak Hill Capital Partners, and the directors of one of its portfolio companies (both outsiders and those designated by the fund) were sued for breach of fiduciary duty and other claims in connection with the redemption of preferred stock held by the fund. The court’s refusal to dismiss the case creates the potential for a long and expensive court battle and ultimately the possibility of liability for Oak Hill and the directors.

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What Drives Differences in Management?

Nicholas Bloom is the William Eberle Professor of Economics at Stanford University, a Senior Fellow of the Stanford Institute for Economic Policy Research, and the Co-Director of the Productivity, Innovation and Entrepreneurship program at the National Bureau of Economic Research. This post is based on a recent paper authored by Professor Bloom; Erik Brynjolfsson, Director of the MIT Initiative on the Digital Economy, Professor at MIT Sloan School, and Research Associate at NBER; Itay Saporta-Eksten, Assistant Professor of Economics at Tel Aviv University; John Van Reenen, Professor, MIT Department of Economics and Sloan School of Management; and Megha Patnaik, Stanford University.

The focus of good corporate governance is making sure executives run their firms well. But how do we define success? One way is to look at performance in terms of profits, stock-prices or growth. But all these measures have a major component of luck and may be very poor signals of managerial quality. As any sports fan knows if your players are unlucky it’s hard to win games no matter how great a manager you are.

So how can we get a more direct measure of management skill?

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LTIP-ing Point: Is This the End of Long-Term Incentive Plans?

Nick Dawson is Co-Founder & Managing Director at Proxy Insight. This post is based on a Proxy Insight publication. Related research from the Program on Corporate Governance includes: Paying for Long-Term Performance by Lucian Bebchuk and Jesse Fried (discussed on the Forum here).

Long-Term Incentive Plans (LTIPs) seem to have become the latest focus point for shareholder anger over executive compensation. Most recently, a group of MPs called on the U.K. Government to ban LTIPs from next year, claiming that they create “perverse” incentives and encourage short-term decisions.

LTIPs usually constitute the largest element of executive pay, and are typically three years in length. Around 90% of FTSE 100 companies used LTIPs in 2013, up from 30% in the mid-1990s. Over the same period, the average LTIP payout to a FTSE 100 lead executive increased from 40% of pay to more than 200%.

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Weekly Roundup: May 5–May 11, 2017


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This roundup contains a collection of the posts published on the Forum during the week of May 5–May 11, 2017.
















An Activist View of CEO Compensation

David Larcker is James Irvin Miller Professor of Accounting at Stanford Graduate School of Business; Brian Tayan is a Researcher with the Corporate Governance Research Initiative at Stanford Graduate School of Business. This post is based on a paper authored by Professor Larcker; Mr. Tayan; G. Mason Morfit, Partner and President of ValueAct Capital; D. Robert Hale, Partner at ValueAct Capital; and Alex Baum, Vice President at ValueAct Capital. Related research from the Program on Corporate Governance includes: Paying for Long-Term Performance by Lucian Bebchuk and Jesse Fried (discussed on the Forum here).

We recently published a paper on SSRN, An Activist View of CEO Compensation, that explains a framework developed by activist fund ValueAct Capital for evaluating executive compensation plans.

Understanding CEO compensation plans is a continuing challenge for boards of directors and investors. Disclosure rules and general industry practices rely heavily on calculating the “fair value” of compensation awards as of the grant date. The problem with this approach is that the fair value of awards is a static (expected) number that does not reflect how a plan scales to performance. The relation between pay and performance can sometimes be discerned from the details of SEC filings but they are not made explicit and often do not make it into the analyses upon which boards of directors make compensation decisions.

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The Trouble with Trulia: Re-Evaluating the Case for Fee-Shifting Bylaws as a Solution to the Overlitigation of Corporate Claims

William B. Chandler III is a partner at Wilson Sonsini Goodrich & Rosati and former Chancellor of the Delaware Court of Chancery. Anthony A. Rickey is a solo practitioner at Margrave Law LLC. This post is based on a paper first presented at a symposium of the Lowell Milken Institute for Business Law and Policy at the UCLA School of Law. This post is part of the Delaware law series; links to other posts in the series are available here.

Confronted with a dramatic rise in deal litigation “beyond the realm of reason” in the early part of the 21st century, [1] Delaware’s legal community struck a grand bargain with its corporate citizens. As a first step, the legislature prohibited Delaware stock companies from enacting fee-shifting bylaws in the wake of the Delaware Supreme Court’s ruling in ATP Tour, Inc. v. Deutscher Tennis Bund, [2] despite the potential for such measures to deter “merger tax” lawsuits. Some saw fees-shifting bylaws as a threat to Delaware’s legal community, and others—including the Delaware State Bar Association (“DSBA”) and the plaintiffs’ bar—considered their likely effect on stockholder lawsuits to be “throwing the baby out with the bathwater.” In the course of promoting this legislation, the DSBA explicitly encouraged greater scrutiny of intracorporate litigation by the judiciary, and the adoption of forum selection bylaws by corporations, as an alternate means of reducing the incidence of socially wasteful litigation.

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Lessons Beyond Corwin: Columbia Pipeline and Saba Software

Jason M. Halper is a partner at Cadwalader, Wickersham & Taft LLP. This post is based on a Cadwalader publication by Mr. Halper, Alejandra Contreras, and Hyungjoo Han. This post is part of the Delaware law series; links to other posts in the series are available here.

Two recent decisions from the Delaware Court of Chancery faithfully apply the Delaware Supreme Court’s holding in Corwin v. KKR Financial Holdings LLC. No surprise there. Corwin held that when “a transaction not subject to the entire fairness standard is approved by a fully informed, uncoerced vote of the disinterested stockholders, the business judgment rule applies.” That is so even if, pre-Corwin, an all-cash merger otherwise would have been subject to enhanced scrutiny under Revlon.

The significance of the two recent lower court decisions—In re Columbia Pipeline Group, Inc. Stockholder Litigation and In re Saba Software, Inc. Stockholder Litigation—lies not in the fact that they applied Corwin, but how each did so on the facts alleged in the complaints. In reaching opposite results (dismissal of the complaint in Columbia and denial of a motion to dismiss in Saba), the decisions provide important guidance regarding, among other things, the types of disclosures that are material; the appropriate oversight and handling of a sales process by a board and its financial advisor; circumstances that suggest a coerced stockholder vote; and the scope of aiding and abetting liability for the buyer.

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Financial Markets and the Political Center of Gravity

Mark Roe is a professor at Harvard Law School. This post is based on a recent paper authored by Professor Roe and Travis Coan, lecturer in politics at the University of Exeter.

In Financial Markets and the Political Center of Gravity, Travis Coan and I investigate the link between left-right market-friendliness across the developed world and financial markets. Academics across multiple disciplines and policymakers in multiple institutions have in recent decades searched for the economic, political, and institutional foundations for financial market strength. Promising theories and empirics have developed, including major explanations from differences in nations’ political economy.

A common view among multiple academic observers is that, particularly because many pro-market corporate reforms occurred during the 1990s in Europe, when social democratic parties governed and financial markets deepened, basic left-right explanations fail to explain financial market strength. Hence, more complex political explanations are needed, and the correlation of left governments, market-oriented reforms, and financial deepening present an unexpected paradox. This finding might be interpreted to indicate that left-right orientation is unimportant in affecting financial development and that either nonpolitical institutional issues or different political considerations are more central.

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Guarding Against Challenges to Director Equity Compensation

P. Rupert Russell is a partner and Jiang Bian is an associate at Shartsis Friese LLP. This post is based on a Shartsis Friese publication by Mr. Russell and Mr. Bian.

There has been an emerging litigation trend in Delaware, where most U.S. public companies are incorporated, alleging that directors breached their fiduciary duties and committed waste of corporate assets in granting themselves excessive awards under the company’s equity compensation plan. [1] Because directors have a direct interest in their own pay, Delaware courts have held that board decisions on director compensation do not receive the protection of the business judgment rule without proper stockholder ratification.

When dealing with stockholder lawsuits, the often crucial issue faced by many public companies is whether they can avoid discovery. If a stockholder lawsuit can survive a motion to dismiss, the nuisance nature of discovery may significantly increase the case’s settlement value, regardless of whether the plaintiff can eventually prevail. Absent the protection of the business judgment rule, it could be difficult to dismiss stockholder complaints at the pleadings stage, and the corporate defendants may face an unpleasant choice between continued litigation with all of its risks and distractions or a costly settlement.

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Saving Investors from Themselves: How Stockholder Primacy Harms Everyone

Frederick Alexander is Head of Legal Policy at B Lab. This post is based on Mr. Alexander’s recent article, published in the Seattle University Law Review.

Communities around the world face many difficult issues, including poverty, climate change, social and economic inequality, the cost and quality of education and healthcare, stagnant wages, financial market instability, disease, and food security. Despite the existential threat that these concerns may raise, there is no consensus on whether or how to address them through regulation, taxation, or other government policy tools. Private enterprise, however, has tremendous potential to address these issues through technology, wages, supply chain maintenance, green operations, efficient delivery of goods and services, and a myriad of other outputs and outcomes. In the U.S., the potential of the private sector to address these issues dwarfs that of the government. The 2015 federal budget was approximately $2.5 trillion (excluding transfer payments like Social Security), while the 2015 gross domestic product (GDP) was about $18 trillion. While numbers go up and down, total government spending (including state and local) typically accounts for about 20% of GDP when transfer spending is netted out. Consumer and business spending account for the other 80%.

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