Sanford Lewis is the Director at Shareholder Rights Group. This post is a based on a Shareholder Rights Group rulemaking petition by Mr. Lewis, Steven Rothstein, Dave Wallack, Josh Zinner, Thomas DiNapoli, and Bryan McGannon.
I. Introduction
The undersigned submit the following pursuant to 17 CFR § 201.192(a) (Rule 192(a) of the Commission’s Rules of Practice) and Section 553 of the Administrative Procedure Act.
Petitioners request that the Commission, in any rulemaking to amend Rule 14a-8 under the Securities Exchange Act of 1934 (“the Rule”), largely retain the Rule, which has, over the course of many decades established and refined a balance among issuers, proponents, and the voting shareholders whose capital is at stake.
The petition addresses both the no-action process as well as the underlying exclusion and procedural rules. We urge that both be retained and staff review be restored effective immediately.
Comment Letter on the Proposed Semiannual Reporting Rule
More from: Nell Minow, ValueEdge Advisors
Nell Minow is the Vice Chair at ValueEdge Advisors. This post is based on her SEC comment letter.
I write in strong opposition to the proposal to reduce reporting to file semiannual reports on the new Form 10-S in lieu of quarterly reports on Form 10-Q. I note that this was prepared entirely by me, without the aid of AI or any LLMs.
I agree with many of the thoughtful comments from investors, like the excellent comment from Marcie Frost, CEO of CalPERS, especially this:
If the Commission’s objective is to lengthen corporate decision-making horizons, then the more effective and well-targeted lever, as we have urged in prior comment letters, is to discourage the voluntary issuance of forward quarterly earnings guidance, not to dilute the historical financial reporting on which investors depend.
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