I write on behalf of the Council of Institutional Investors (CII), a nonprofit, nonpartisan association of U.S. public, corporate and union employee benefit funds, other employee benefit plans, state and local entities charged with investing public assets, and foundations and endowments with combined assets under management of approximately $5.2 trillion. Our member funds include major long-term shareowners with a duty to protect the retirement savings of millions of workers and their families, including public pension funds with more than fifteen million participants – true “Main Street” investors through their pension funds. Our associate members include non-U.S. asset owners with about $5.8 trillion in assets, and a range of asset managers with more than $74 trillion in assets under management.[1]

CII values the opportunity to respond to the SEC’s notice dated December 23, 2025, that it is instituting proceedings on whether to approve or disapprove Nasdaq’s proposed rule regarding the adoption of additional initial listing criteria for companies primarily operating in China.[2] Nasdaq submitted this proposal dated September 3, 2025, in which it seeks a minimum $25 million in proceeds from newly listed companies, along with two other changes concerning Chinese companies, for review by the Securities and Exchange Commission (SEC).

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