Yearly Archives: 2019

Shareholder Protection and the Cost of Capital

Joel F. Houston is the Eugene F. Brigham Chair in Finance at the Warrington College of Business at the University of Florida; Chen Lin is the Stelux Professor in Finance at The University of Hong Kong; and Wensi Xie is Assistant Professor at The Chinese University of Hong Kong. This post is based on their recent article, forthcoming in the Journal of Law and Economics.

Do the legal environment and the level of shareholder protection meaningfully influence the cost of capital? To shed some light on this issue, our recent article Shareholder Protection and the Cost of Capital (which is forthcoming in the Journal of Law and Economics) explores how changes in shareholders’ rights affect their required risk premium, which in turn generates important influences on both corporate valuations and the overall depth of financial markets. Intuitively, when outside shareholders invest in jurisdictions with stronger investor protections, they recognize that insiders are less likely to divert firm resources for their own private benefits. Shareholders factoring this lower risk of expropriation into their valuation model are therefore willing to pay more for firms’ equity, which in turn enables firms to obtain external financing with better terms.

Specifically, we focus on shareholders litigation rights, which entitle them to make legal claims against corporate management. To isolate the effects of shareholder litigation rights, we employ a quasi-natural experiment where we examine the impact of staggered state-level changes in universal demand (UD) laws on firms’ cost of capital. Since the late 1980s, 23 states in the U.S. have adopted these universal demand laws. The adoption of UD laws has significantly weakened shareholders’ litigation rights by raising procedural hurdles to pursue derivative lawsuits. (Davis 2008; Erickson 2010). When a firm’s management breaches its fiduciary duties by causing injuries to the firm, individual shareholders are entitled to bring a derivative suit against the manager to remedy wrongdoing on behalf of the corporation. The universal demand laws, however, impose a “universal demand requirement” to every derivative lawsuit, meaning that the plaintiff shareholder must first make a demand on the board of directors to take corrective actions before proceeding with litigation. This requirement places a significant obstacle to derivative suits because directors are usually the defendants in these suits and hence almost always refuse to proceed with litigation. Moreover, the shareholder can no longer circumvent the demand procedure by arguing demand futility on the grounds that directors have a conflict of interest. Using information on companies’ derivative lawsuits collected from their SEC 10-K filings, we confirm that the occurrence of derivative litigations drops materially following the passage of UD laws. In this regard, UD laws weaken shareholder litigation rights by making it more difficult for shareholders to seek remedies and enforce fiduciary duties through derivative suits.

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SEC Staff Guidance on Shareholder Proposals: A Murky Path Forward

Marc Gerber is partner, Hagen Ganem is counsel and Ryan Adams is an associate at Skadden, Arps, Slate, Meagher & Flom LLP. This post is based on their Skadden memorandum.

In November 2017, the staff of the Division of Corporation Finance (Staff) of the Securities and Exchange Commission (SEC) issued guidance concerning companies’ ability to exclude shareholder proposals from their proxy statements under the “ordinary business” and “relevance” grounds of Rule 14a-8. In particular, Staff Legal Bulletin No. 14I (SLB 14I) invited companies to include in their no-action requests their board’s analysis of the significance of a proposal under these exclusions, emphasizing that a well-developed discussion of that analysis would assist the Staff in its review of these requests. Virtually every company that went down this path, however, was unsuccessful, and after the 2018 proxy season many questioned the utility of providing a board analysis.

Perhaps due to this skepticism, heading into the 2019 proxy season the Staff released guidance in Staff Legal Bulletin No. 14J (SLB 14J) that, among other things, reiterated its view that a board analysis could be helpful in analyzing no-action requests and provided a nonexclusive list of items that might be included in a “well-developed discussion.” In addition, SLB 14J provided guidance concerning the micromanagement prong of the ordinary business exclusion and on proposals relating to senior executive compensation. While this guidance led to an increase in successful micromanagement arguments, it also created confusion for companies seeking to exclude proposals touching on senior executive compensation.

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How Boards Govern Disruptive Technology—Key Findings from a Director Survey

Steve W. Klemash is Americas Leader and Jennifer Lee is Senior Manager at the EY Center for Board Matters; and Kris Pederson is Corporate Governance Leader, Americas Advisory at EY. This post is based on their joint EY and Corporate Board Member memorandum.

Technology can enable innovation and disrupt existing business models. Many corporate leaders are increasingly considering how technology can improve operational efficiencies, create new products and services, and help their organizations enter untapped markets. They are also surveying the landscape for competitive entrants seeking to disrupt their industry.

Of course, adopting new technology can be challenging and have far-reaching effects both inside and outside of an organization. While many of these can be positive, others can lead to unforeseen risks and unintended consequences. For instance, implementation can bring about risks related to alignment with new or existing business models, resources and training, security and data management, and overall project management, to name just a few.

Overlooking the opportunities and risks related to disruptive technology can be costly, but so too can a rush to implement it. In this report, Corporate Board Member and EY present the key findings of a survey of 365 corporate directors on the topic of disruptive technology. Here’s what we found:

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Deal Insurance: Representation & Warranty Insurance in M&A Contracting

Sean J. Griffith is T.J. Maloney Chair and Professor of Law at Fordham Law School. This post is based on his recent article, forthcoming in the Minnesota Law Review. Related research from the Program on Corporate Governance includes M&A Contracts: Purposes, Types, Regulation, and Patterns of Practice, and Allocating Risk Through Contract: Evidence from M&A and Policy Implications (discussed on the Forum here) both by John C. Coates, IV.

Parties to M&A transactions now commonly purchase insurance against breaches of the reps and warranties. In a forthcoming article, I study Representation and Warranty Insurance (“RWI”) in the U.S. market using two empirical methodologies. First, I survey nearly 100 market participants in the market—insurers, brokers, lawyers, and private equity managers. And second, I analyze the terms of over 400 merger agreements, comparing the terms of insured and uninsured deals. The full study is available here. These are the basics of what I found:

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SEC Rules and Guidance for Broker-Dealers and Investment Advisers

Jessica Forbes and Stacey Song are partners and Joanna D. Rosenberg is an associate at Fried, Frank, Harris, Shriver & Jacobson LLP. This post is based on their Fried Frank memorandum. Related research from the Program on Corporate Governance includes The Trilateral Dilemma in Financial Regulation by Howell E. Jackson (discussed on the Forum here).

On June 5, 2019, the Securities and Exchange Commission (the “SEC”) voted 3-1 to adopt the highly anticipated rulemaking package addressing investment adviser and broker-dealer standards of conduct. The package includes final versions of (i) the SEC’s interpretation of the standard of conduct for investment advisers (“Final Interpretation”), [1] (ii) new rules to require registered advisers and registered broker-dealers to provide to retail investors a relationship summary (“Form CRS”), [2] (iii) a new rule establishing a standard of conduct for broker-dealers when making recommendations to retail customers (“Regulation Best Interest”), [3] and (iv) the SEC’s interpretation of the “solely incidental” prong of the broker-dealer exclusion from the definition of investment adviser (“Broker-Dealer Exclusion Interpretation”) in the Investment Advisers Act of 1940 (the “Advisers Act”). [4] We discuss each of the rules and interpretations below.

The Fiduciary Duty Interpretation

As with the proposed interpretation of the standard of conduct for investment advisers (the “Proposed Interpretation”), [5] the Final Interpretation includes a discussion of existing SEC guidance and case law regarding an investment adviser’s federal fiduciary duty. This fiduciary duty, which is made enforceable by the antifraud provisions of the Advisers Act, consists of a duty of care and a duty of loyalty. An adviser’s duty of care includes the duty to provide advice that is in the client’s best interest, including a duty to provide advice that is suitable for the client, as well as a duty to seek best execution (if applicable) and a duty to provide advice and monitoring over the course of the relationship (as applicable and agreed upon with the client). An adviser’s duty of loyalty includes the duty to not subordinate a client’s interests to its own, as well as a duty to make full and fair disclosure of all material facts relating to the advisory relationship (including the capacity in which it is acting with respect to the advice provided) and to obtain the client’s informed consent to conflicts of interest. The Final Interpretation clarifies that an adviser’s fiduciary duty applies to all investment advice, including advice about investment strategy, engaging a sub-adviser, and account type. We highlight below our key observations from the Final Interpretation, including notable clarifications and distinctions from the Proposed Interpretation.

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Irrelevance of Governance Structures

Zohar Goshen is the Jerome L. Greene Professor of Transactional Law at Columbia Law School and Doron Levit is Assistant Professor of Finance at The Wharton School of the University of Pennsylvania. This post is based on their recent paper.

The central theme in the theory of corporate governance is that allocating more control rights to shareholders will allow them to hold disloyal managers accountable and reduce agency costs. The common empirical prediction that follows is that a weak governance structure will be associated with weak firm value and performance due to high agency costs. However, a review of empirical studies of the last forty years reveals that every aspect of corporate governance that was studied yielded conflicting empirical findings as to its effect on firm value and performance. For instance: the level of cash flow rights held by management; dual-class firms; anti-takeover defenses, such as poison pills, staggered boards, and protective state legislations; hedge-fund activism; and the strength of corporate governance as measured by several indices.

Interestingly, despite the inconclusive empirical evidence, institutional investors with common ownership are consistently pushing toward strong governance structure for publicly traded firms, via, for instance, destaggering boards, limiting the use of poison pills, excluding dual-class firms from the indices, demanding mandatory sunsets for dual-class firms, and supporting hedge funds’ governance initiatives.

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Post-Cyan Ruling on Discovery Stay

Vincent Sama is a partner and Brendan Gibbons is an associate at Arnold & Porter Kaye Scholer LLP. This post is based on their Arnold & Porter memorandum.

In May 15, 2019, a Connecticut Superior Court found that defendants in a claim under the Securities Act of 1933 (Securities Act) were entitled to the mandatory discovery stay pending a motion to dismiss under the Private Securities Litigation Reform Act of 1995 (PSLRA)—a significant ruling due to its reasoning and the possibility that other state courts may follow the decision.

Background

The Securities Act states that suits brought under the Act may be filed in either state or federal courts and includes an anti-removal provision that prevents defendants from removing a case from state to federal court.

The Securities Act also allows for class-action suits. In 1995, in order “to stem perceived abuses of the class-action vehicle,” Congress amended the Securities Act and the Securities Exchange Act of 1934 (the primary mechanism for bringing anti-fraud class action suits) and enacted the PSLRA. In its discovery stay subsection, the PSLRA states: “In any private action arising under this subchapter, all discovery and other proceedings shall be stayed during the pendency of any motion to dismiss, unless the court finds, upon the motion of any party, that particularized discovery is necessary to preserve evidence or to prevent undue prejudice to that party.”

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Baby on Board: Remarks before the Society for Corporate Governance National Conference

Hester M. Peirce is a Commissioner at the U.S. Securities and Exchange Commission. This post is based on her recent remarks before the Society for Corporate Governance National Conference, available here. The views expressed in this post are those of Ms. Peirce and do not necessarily reflect those of the Securities and Exchange Commission or its staff.

A few months ago there was an article in the Washington Post about the baby on board signs that seem to be on so many cars. [1] The article’s timing was perfect because I had just seen one of those signs and remember wondering why they seemed to be making a come-back. At one point, those signs were everywhere, on almost every car. Then they seemed to disappear for a while, but now they are back. The article gave the history of the signs, which first hit rear windows in 1986, assessed the psychology behind their popularity, and reported on people’s reaction to them. The article speculates that for parents driving their infants around on dangerous roadways, these signs serve as “protective talismans.” Less superstitious parents might also use the signs to signal emergency responders in case of an accident that there is a baby in the car. Other drivers see the signs as a way of announcing to the world that you are a parent or as pleas for others to drive carefully. At bottom, the article suggests, the signs seem to reflect a jumble of parental emotions—anxiety, pride, love, and deep respect for the preciousness of life. Also reflecting a jumble of emotions, is the recent “Lady on Board” trend. Before I turn to this topic, I better give my disclaimer. The views that I represent are my own and not necessarily those of the Securities and Exchange Commission or my fellow Commissioners.

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Spotlight on Boards

Martin Lipton is a founding partner of Wachtell, Lipton, Rosen & Katz, specializing in mergers and acquisitions and matters affecting corporate policy and strategy. This post is based on a Wachtell Lipton memorandum by Mr. Lipton and is part of the Delaware law series; links to other posts in the series are available here.

The ever-evolving challenges facing corporate boards prompt periodic updates to a snapshot of what is expected from the board of directors of a major public company—not just the legal rules, or the principles published by institutional investors and various corporate and investor associations, but also the aspirational “best practices” that have come to have equivalent influence on board and company behavior. A very significant June decision by the Delaware Supreme Court interpreting the Caremark doctrine that limits director liability for an oversight failure to “utter failure to attempt to assure a reasonable information and reporting system exists” prompts this update. Our memo discussing the decision is available here. The Court said to “satisfy their duty of loyalty,” “directors must make a good faith effort to implement an oversight system and then monitor it” themselves.  Without more, the existence of management-level compliance programs is not enough for the directors to avoid Caremark exposure. Today, boards are expected to:

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Dual-Class Shares: Governance Risks and Company Performance

Kosmas Papadopoulos is Managing Editor at ISS Analytics. This post is based on an ISS Analytics memorandum by Mr. Papadopoulos. Related research from the Program on Corporate Governance includes The Untenable Case for Perpetual Dual-Class Stock (discussed on the Forum here), and The Perils of Small-Minority Controllers (discussed on the Forum here), both by Lucian Bebchuk and Kobi Kastiel, and the keynote presentation on The Lifecycle Theory of Dual-Class Structures.

Initial public offerings of companies with dual-class shares have made headlines in recent years. An increasing number of newly listed companies have introduced classes of stock with superior voting rights, which typically allow company founders and top executives to maintain company control even as their economic stake in the business may diminish. Dual-class companies include some of the most successful and highly-valued companies in the world, such as corporate giants Facebook Inc., Alphabet Inc. (parent of Google), and Berkshire Hathaway Inc. In 2019, some of the largest U.S. IPOs involved classes of stock with superior voting rights, including ride-hailing services company Lyft Inc., social media platform Pinterest Inc., and jeans maker Levi Strauss & Co.

Many investors and corporate governance experts sound the alarm about the growing prevalence of dual-class share structures, given the potential risks that such ownership arrangements pose to common shareholders. They argue that the discrepancy between control and economic ownership reduces accountability to the economic owners of the business, entrenching management and skewing incentives. Meanwhile, proponents of the dual-class share structure contend that control is necessary to protect the company from the short-term pressures of the market and to allow management to focus on growth and long-term strategy.

In this post, we review some of the key trends in dual-class share structures in the U.S., and we examine the links between dual-class share structures with corporate governance and company performance. Based on our analysis, we highlight the following key findings:

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