Yearly Archives: 2021

Board Readiness for Shareholder Activism

Paul DeNicola is Principal at the Governance Insights Center, PricewaterhouseCoopers LLP. This post is based on his PwC memorandum. Related research from the Program on Corporate Governance includes The Long-Term Effects of Hedge Fund Activism by Lucian Bebchuk, Alon Brav, and Wei Jiang (discussed on the Forum here); Dancing with Activists by Lucian Bebchuk, Alon Brav, Wei Jiang, and Thomas Keusch (discussed on the Forum here); and Who Bleeds When the Wolves Bite? A Flesh-and-Blood Perspective on Hedge Fund Activism and Our Strange Corporate Governance System by Leo E. Strine, Jr. (discussed on the Forum here).

For many people, proxy fights are almost synonymous with shareholder activism. But we view them as just one point on an activism continuum that also includes investors’ engagement with companies whose shares they hold, shareholder proposals, and more. Whenever an investor leverages their rights and privileges as an owner to influence a company’s practices or strategy, that’s shareholder activism.

Increasingly, investors of all kinds are using the full spectrum of activist tools to weigh in on environmental, social, and governance (ESG) issues. Indeed, it’s likely 2021 will be remembered as the year that ESG became a key part of shareholder activists’ strategies.

A handful of newly-launched ESG-focused activist firms and their high-profile proxy contests are a big part of the reason why. In addition, large institutional investors have reported that they’re engaging with companies around climate risk disclosures, D&I, and other ESG topics with much greater frequency. Some have said they increasingly chose to vote against directors at companies they felt weren’t handling these matters appropriately. And the number of shareholder proposals focused on environmental and social matters that received majority support reached a record high during the 2021 proxy season.

What connects all these activities—from engagement to proxy contests—is how they demonstrate many shareholders’ conviction that good performance on ESG-related matters builds value, while poor performance destroys it. Obviously, companies and their boards can’t afford to take those views lightly. It’s more important than ever for directors to take a holistic view of shareholder activism and to understand their role in navigating the challenges it may pose.

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SEC Highlighting the Need to Consider Climate Change Disclosures in SEC Filings

Michael Littenberg is partner and Marc Rotter is counsel at Ropes & Gray LLP. This post is based on their Ropes & Gray memorandum. Related research from the Program on Corporate Governance includes The Illusory Promise of Stakeholder Governance (discussed on the Forum here) and Will Corporations Deliver Value to All Stakeholders?, both by Lucian A. Bebchuk and Roberto Tallarita; For Whom Corporate Leaders Bargain by Lucian A. Bebchuk, Kobi Kastiel, and Roberto Tallarita (discussed on the Forum here); and Restoration: The Role Stakeholder Governance Must Play in Recreating a Fair and Sustainable American Economy—A Reply to Professor Rock by Leo E. Strine, Jr. (discussed on the Forum here).

In late September, the staff of the SEC’s Division of Corporation Finance published a sample comment letter relating to climate change disclosures. While the sample letter does not break new ground substantively, it underscores the SEC’s increasing focus on climate disclosures and its views more generally on the relevance to investors of climate-related risks. In this post, we discuss the sample comment letter and take-aways for public companies.

A Bit of Background—the SEC Turns up the Heat on Climate Disclosure

Since the change in administration, the SEC’s focus on climate disclosure has been increasing. In early February, Satyam Khanna was named Senior Policy Advisor for Climate and ESG to then-Acting Chair Allison Herren Lee. Later that month, Acting Chair Lee issued a Statement indicating she was directing the Division of Corporation Finance to enhance its focus on climate-related disclosure in public company filings. The Statement indicated that, as part of its enhanced focus in this area, the staff would (1) review the extent to which public companies are addressing the topics identified in the SEC’s 2010 climate risk guidance, (2) assess compliance with disclosure obligations under the federal securities laws, (3) engage with public companies on these issues and (4) absorb critical lessons on how the market is currently managing climate-related risks.

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The Stablecoins Debate

David L. Portilla is partner and Will C. Giles is senior attorney at Cravath, Swaine & Moore LLP. This post is based on their Cravath memorandum.

In 1982 E. Gerald Corrigan, then president of the Federal Reserve Bank of Minneapolis, asked “Are Banks Special?” [1] He did so at the behest of Paul Volcker when Volcker was chairman of the Federal Reserve Board and at a time when there was “rapid change, with market innovation and new sources of competition” to banks from nonbanks and the “perception that banks’ competitive position—and presumably their market share—has slipped”. [2] Corrigan’s paper provided an approach to think about the future scope of banking activities and bank structure that, in hindsight, appears to have predicted largely how banking law would evolve for at least the next 20 years after his writing. [3]

At a time when we once again see a rapid pace of innovation in the financial sector and banks are facing increased competition from new nonbank innovators, we thought it appropriate to turn back to Corrigan’s perceptive and influential work to see what lessons it can offer. As described below, his analysis provides yet another lens through which to view the stablecoin debate. Moreover, his struggles with how to consider money market mutual funds (“MMFs”) helps inform the debate, given not only that MMFs and stablecoins have similarities, but also that MMFs were, at the time of the essay (as stablecoins are now), relatively small, new and novel financial products.

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ESG Regulatory Reform

Katie McShane is an associate at Cadwalader, Wickersham & Taft LLP. This post is based on her Cadwalader memorandum. Related research from the Program on Corporate Governance includes The Illusory Promise of Stakeholder Governance (discussed on the Forum here) and Will Corporations Deliver Value to All Stakeholders?, both by Lucian A. Bebchuk and Roberto Tallarita; For Whom Corporate Leaders Bargain by Lucian A. Bebchuk, Kobi Kastiel, and Roberto Tallarita (discussed on the Forum here); and Restoration: The Role Stakeholder Governance Must Play in Recreating a Fair and Sustainable American Economy—A Reply to Professor Rock by Leo E. Strine, Jr. (discussed on the Forum here).

With ESG (Environmental, Social and Governance) funds on a dramatic incline, an incline expected to continue going forward, it seems inevitable that regulatory reform is on the horizon. Europe has been leading the charge in the incorporation of ESG considerations into its regulatory framework. As we look to gauge what type of regulatory reform might be around the corner for us here in the U.S., specifically in the realm of fund finance, it is useful to look at the regulatory developments in the EU.

Regulatory Reform in the EU

The most relevant EU regulation in this space is the Sustainable Finance Disclosure Regulation (SFDR), which came into effect in March of this year. The SFDR imposes mandatory ESG disclosure obligations on asset managers and other financial markets participants, and is a major milestone in the EU’s efforts to ensure a systematic and transparent approach to sustainability within financial markets, thereby preventing greenwashing and ensuring comparability.

By way of background, the SFDR was introduced by the European Commission alongside the Low Carbon Benchmarks Regulation and the Taxonomy Regulation as part of a package of legislative measures stemming from the European Commission’s Action Plan on Sustainable Finance.

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Boards Increase Transparency and Pursue Growth

Amy Rojik is Director and Founder of the BDO Center for Corporate Governance. This post is based on her BDO memorandum.

Introduction

As an uncertain business environment persists, board directors face expanding roles and responsibilities in applying the lessons learned over the past 18 months while continuing to navigate new obstacles. In our last Board Pulse Survey, directors indicated they were challenged by an array of financial, operational and regulatory pressures as the wide range of stakeholders expanded their expectations of the board’s role. In addition to those issues, board members face new regulatory changes, issues related to globalization and digital acceleration, and the rise of environmental, social and governance (ESG) factors being linked to company performance. All of these elements will play a pivotal role as boards look to thrive in today’s shifting corporate climate.

While keeping these challenges top of mind, boards are optimistic and taking active steps toward growth. Our 2021 BDO Fall Board Pulse Survey explores the evolving corporate strategies for public company boards of directors, including how they plan to pursue growth and increase transparency around strategic shifts.

Key Findings

  • Coming out of the 2021 proxy season, engagement of shareholders and investors is priority #1.
  • M&A is the top-ranked corporate strategy.
  • Cybersecurity and data privacy continue to be significant governance issues for all companies.
  • Risk of supply chain disruption challenges boards to tackle sourcing diversification head-on.
  • Labor shortages and scrutiny around board composition encourage more thoughtful talent recruitment and refreshment processes.
  • ESG issues remain high on boards’ priority lists, as directors explore options on how best to comply with changing requirements and communicate their efforts publicly.
  • With annual reporting approaching, boards anticipate challenges around increasing disclosures and risks.

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​U.S. DOL Proposes ESG-Related Updates to the ERISA Investment Duties Regulation

Heather L. Coleman, Eric M. Diamond, and Marc Treviño are partners at Sullivan & Cromwell LLP. This post is based on a Sullivan & Cromwell memorandum by Ms. Coleman, Mr. Diamond, Mr. Treviño, Jonathan B. Beek, and Samuel E. Saunders. Related research from the Program On Corporate Governance includes The Illusory Promise of Stakeholder Governance by Lucian A. Bebchuk and Roberto Tallarita (discussed on the Forum here); Companies Should Maximize Shareholder Welfare Not Market Value by Oliver Hart and Luigi Zingales (discussed on the Forum here); Reconciling Fiduciary Duty and Social Conscience: The Law and Economics of ESG Investing by a Trustee by Max M. Schanzenbach and Robert H. Sitkoff (discussed on the Forum here); and Will Nasdaq’s Diversity Rules Harm Investors? by Jesse M. Fried (discussed on the Forum here).

Summary

On October 13, 2021, the U.S. Department of Labor (“DOL”) announced a proposed rulemaking to amend the Investment Duties regulation under Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”) that would clarify the application of ERISA’s plan fiduciary duties of prudence and loyalty to selecting investments and investment courses of action, including selecting qualified default investment alternatives (“QDIAs”), and to exercising shareholder rights, including proxy voting. [1] While the proposal retains the core principle that the duties of prudence and loyalty require ERISA fiduciaries to focus on material risk-return factors, the proposal is intended to remove barriers implemented by the prior administration that the DOL believes limited fiduciaries’ ability to consider climate change and other ESG matters as factors when selecting investments and exercising shareholder rights. Title I governs private pension plans.

As described in greater detail below, significant points from the proposed rule include changes to:

  • Clarify the permissibility of consideration of climate change and other ESG factors, including governance and workforce factors, on particular investments or investment courses of action;
  • Apply the same investment standards to QDIAs, such that otherwise qualified QDIAs may include consideration of ESG factors;
  • Improve and clarify application of the “tie-breaker” test, which permits fiduciaries to consider collateral benefits as tie-breakers in some circumstances; [2] and
  • Increase the likelihood of fiduciaries exercising voting and other shareholder rights while reducing associated administrative burdens.

The proposal has been anticipated since President Biden took office and follows a range of measures in the E.U. (the Sustainable Finance Disclosure Regulation, among others), the U.K. (the Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021, among others) and elsewhere aimed at enhancing (or mandating) pension plan consideration of climate change and other ESG factors.

Comments on the proposed rule are due by December 13, 2021.

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First Legal Challenge to California’s Board Gender Diversity Statute Heads to Trial

Cydney S. Posner is special counsel at Cooley LLP. This post is based on her Cooley memorandum. Related research from the Program on Corporate Governance includes Politics and Gender in the Executive Suite by Alma Cohen, Moshe Hazan, and David Weiss (discussed on the Forum here); and Will Nasdaq’s Diversity Rules Harm Investors? by Jesse M. Fried (discussed on the Forum here).

You might remember that the first legal challenge to California’s board gender diversity statute, Crest v. Alex Padilla, was a complaint filed in 2019 in California state court by three California taxpayers seeking to prevent implementation and enforcement of the law. Framed as a “taxpayer suit,” the litigation sought to enjoin Alex Padilla, the then-California Secretary of State (now U.S. Senator), from expending taxpayer funds and taxpayer-financed resources to enforce or implement the law, SB 826, alleging that the law’s mandate is an unconstitutional gender-based quota and violates the California constitution. The court in that case has just denied each side’s motion for summary judgment after concluding that there were triable issues of material fact. The case will now be going to trial, which is currently set for October 25. Stay tuned.

Even proponents of the California law recognized the possibility of “equal protection” claims and other legal challenges—when Governor Jerry Brown signed the bill into law, he acknowledged that “serious legal concerns” had been raised. (See this PubCo post.) And many expected a flood of legal challenges to frustrate efforts to implement the bill. Nevertheless, California’s businesses appear to have accepted the requirements of the legal mandate—perhaps also feeling the pressure from large asset managers such as BlackRock and State Street—and have not filed suit.

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Weekly Roundup: October 15–21, 2021


More from:

This roundup contains a collection of the posts published on the Forum during the week of October 15–21, 2021.

Delaware Decision Deals with Director Independence



A Guide for Boards and Companies Facing Ransomware Demands


Board Refreshment and Succession Planning in the New Normal


SEC Enforcement Order Highlights Risks of Data-Based Market Intelligence


SEC Comments on Climate Change Disclosure


2021 Corporate Governance Trends in the Retail Industry


Are Star Law Firms Also Better Law Firms?



How to Translate ESG Imperatives into Executive Compensation


Expanding Proxy Voting Choice


Statement by Commissioners Peirce and Roisman on Staff Report on Equity and Options Market Conditions in Early 2021


Court of Chancery Upholds Enforcement of Advance Notice Bylaw


The Capital Structure Puzzle: What are We Missing?


Sustainability Reporting: A Gap Between Words and Action


Boeing: Rejecting Early Dismissal of Claims Against Directors for Inadequate Risk Oversight


Team Production Revisited


Speech by Commissioner Lee on Action on Climate

Speech by Commissioner Lee on Action on Climate

Allison Herren Lee is a Commissioner at the U.S. Securities and Exchange Commission. This post is based on her recent remarks at the PRI/LSEG Investor Action on Climate Webinar. The views expressed in the post are those of Commissioner Lee, and do not necessarily reflect those of the Securities and Exchange Commission or the Staff.

Good morning or good afternoon depending on where you are. I want to start by thanking Principles for Responsible Investment and the London Stock Exchange Group for inviting me to speak today, and for holding this event. I also need to share the standard, but important, disclaimer that the views I express are my own and not those of the Commission or its staff.

This type of dialogue among market participants is a critical component of the larger global effort to come together to address the risk that climate change poses to capital markets and the global economy.

As we move forward on climate initiatives, we must take an approach that is both collaborative and comprehensive. Investors, issuers, standard setters, academics, regulators—we all have a role. At the SEC, our focus is on capital markets—protecting investors, maintaining fair, orderly, and efficient markets, and promoting capital formation. We don’t set emissions standards or net zero targets, we don’t implement carbon pricing, or otherwise shape energy or environmental policy. But we must work hand-in-hand with our colleagues all across government and in the private sector as we fulfill our mission.

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Team Production Revisited

William W. Bratton is Nicholas F. Gallicchio Professor of Law Emeritus at the University of Pennsylvania Carey Law School. This post is based on his recent paper, forthcoming in the Vanderbilt Law Review.

My article, Team Production Revisited, forthcoming in the Vanderbilt Law Review, reviews and reconsiders Margaret Blair and Lynn Stout’s team production model of corporate law (TPM), offering a favorable evaluation.

With the TPM, Blair and Stout set themselves the task of articulating a model of the public corporation that does three things simultaneously. First, the model must be grounded in a microeconomic theory of the firm. Second, the model must be consonant with the provisions and structure of corporate law. Third, the model must situate the accomplishment of productivity outside of the tent of shareholder primacy and market control. Blair and Stout succeeded at the task described, achieving closure for their theory. Indeed, they did something that no one thought could be done.

The model first appeared in the Virginia Law Review in 1999, just as shareholder primacy emerged as corporate law’s consensus view. The TPM challenged the consensus and the agency model on which it centered by widening the descriptive lens. Where the agency model looks only at the shareholder-management contract, the TPM looks at the contracts between the corporation and all capital providers, both financial and human. Where agency model looks for value enhancement only through agency cost reduction, the TPM looks to the production side to encourage firm-specific investment. The TPM also deemphasizes market control, reviving the Coasian stress on hierarchical relationships independent of markets.

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