Author Archives: Harvard Law School Forum on Corporate Governance and Financial Regulation

Investor Pressure on Firearms Manufacturers

The mass shooting at a high school in Parkland Florida has focused renewed attention on the issue of gun violence. While regulators debate the appropriate actions to take, a number of companies and investors have recently made moves to address the issue. For example, both Walmart and Dicks Sporting Goods announced at the end of […]

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Proposed Amendments to Public Reporting of Fund Liquidity Information

Thank you, Chairman Clayton, and thank you to the extraordinary Staff in the Division of Investment Management for all of the hard work reflected in this proposal. I appreciate your and the Staff’s engagement—and your willingness to answer my questions—a great deal. Unfortunately, I cannot join the majority in approving this proposal. The Commission today […]

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Proposed Amendments to Public Reporting of Fund Liquidity Information

I am honored to be here for Dalia Blass’s first open meeting as Director of Investment Management. Dalia has already shown herself to be a fantastic fit for the job. I greatly appreciate the staff’s work on this release. Having sat in your seats during my last stint at the Commission, I know how much […]

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Statement on Proposed Amendments to Public Reporting of Fund Liquidity Information

I would like to join Chairman Clayton in thanking the staff for their work on this release—in particular, Zeena Abdul-Rahman, Thoreau Bartmann, and Sarah ten Siethoff. While I sincerely appreciate the staff’s efforts, I am not persuaded that we should amend our liquidity rule and take useful disclosure away from investors. So what is the […]

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Statement at Open Meeting on Investment Company Liquidity Disclosure

I would first like to thank the Director of the Division of Investment Management, Dalia Blass, for moving this proposal forward. Also, thank you to the staff who worked so hard devising and drafting its contents. I support this recommendation to improve the reporting and disclosure of liquidity information by investment companies. Nevertheless, I am […]

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Weekly Roundup: March 9–15, 2018

Delaware’s Retreat: Exploring Developing Fissures and Tectonic Shifts in Delaware Corporate Law Posted by James D. Cox Duke (Duke University) and Randall S. Thomas (Vanderbilt University), on Friday, March 9, 2018 Tags: Board independence, Boards of Directors, Delaware articles, Delaware cases, Delaware law, Disclosure, Fiduciary duties, Hedge funds, In re Revlon, In re Trulia, Management, Merger litigation, Mergers & acquisitions, Settlements, Shareholder activism, Shareholder suits, Shareholder voting, Unocal v. Mesa The Rise of Blockchains […]

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Statement on Proposed Amendments to Public Reporting of Fund Liquidity Information

Today [March 14, 2018], the Commission will consider a proposed rule that would amend the liquidity risk management rules for open-end funds that the Commission adopted in October 2016. Specifically, staff will recommend that the Commission propose amendments to revise the manner in which information about funds’ liquidity risk management practices is provided to investors […]

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Spring Awakening: Notes from This Year’s CII Meeting

The theme I heard most often at the annual spring meeting of the Council of Institutional Investors was ESG: environmental/social/governance risks and investment opportunities. The issues of how best to understand ESG and factor it into assessing investment risk and return and how to respond as investors through proxy voting or engagement came up in […]

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Overview of Proposed Revisions to the UK Corporate Governance Code

In December 2017, the UK Financial Reporting Council (the “FRC”) proposed revisions to the UK Corporate Governance Code. These revisions will impact companies with a Premium Listing of equity shares in the UK, which are required under the Listing Rules to state in their annual report and accounts how they have applied the Code. The […]

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Remarks to the SEC Investor Advisory Committee

Thank you, Anne (Sheehan), and good morning everyone. I want to extent a special welcome to their first Investor Advisory Committee meeting to Commissioner Robert Jackson and Commissioner Hester Peirce. Hester previously served on, and contributed substantially to, this Committee. Rob and Hester have brought great intellect, energy, and commitment to the Commission. I also […]

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