The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Mon, 07 Sep 2026 11:30:09 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.10 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png SEC Comment Letter Review Signals Investor Support for Preserving Executive Compensation and Governance Disclosure Requirements – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 SEC Comment Letter Review Signals Investor Support for Preserving Executive Compensation and Governance Disclosure Requirements https://corpgov.law.harvard.edu/2026/09/05/sec-comment-letter-review-signals-investor-support-for-preserving-executive-compensation-and-governance-disclosure-requirements/?utm_source=rss&utm_medium=rss&utm_campaign=sec-comment-letter-review-signals-investor-support-for-preserving-executive-compensation-and-governance-disclosure-requirements https://corpgov.law.harvard.edu/2026/09/05/sec-comment-letter-review-signals-investor-support-for-preserving-executive-compensation-and-governance-disclosure-requirements/#respond Sat, 05 Sep 2026 11:30:33 +0000 https://corpgov.law.harvard.edu/?p=183600?d=20260904150053EDT Posted by Mike Kesner and Annie Chen, Pay Governance LLC, on Saturday, September 5, 2026
Editor's Note:

Mike Kesner is a Partner and Annie Chen is a Consultant at Pay Governance LLC. This post is based on their Pay Governance memorandum.

KEY TAKEAWAYS

1. Large institutional investors have not directly weighed in  The largest asset managers have not directly commented on the proposal; an association of these investors indicated support for reform, while suggesting many disclosures remain. 2. Broad rollbacks face resistance
The most consistent message was opposition to $2B NAF status, exemption of 80%+ of issuers, and a blanket five-year IPO on ramp.		 3. Investor respondents value transparency
Investor respondents continue to use CD&A, Say-on-Pay, perquisite disclosure, and auditor attestation for governance and voting decisions.		 4. Reform should focus on usability
Commenters supported better dashboards, standardization, XBRL tagging, improved visuals, clearer metrics, and comparability.

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