December 23, 2021
VIA Electronic Delivery
Vanessa A. Countryman
Secretary
U.S. Securities and Exchange Commission
100 F Street, NE Washington, DC 20549-1090
RE: Comments on the Amendments to the Exemptions from the Proxy Rules for Proxy Voting Advice - Release No. 34-93595; File No. S7-17-21
Dear Ms. Countryman:
The Center On Executive Compensation (“Center”) is pleased to submit comments to the Securities and Exchange Commission (“Commission”) providing its perspective on the SEC’s decision to propose amendments to the recently finalized and not-yet-implemented Rule 14a-2(b)(9)(ii) conditions (proxy solicitation exemption qualifications). The Center believes the Commission’s original 2020 Final Rule represented a set of sensible updates which would have facilitated needed changes to the proxy process. We urge the Commission to allow those changes to take effect before considering further changes, and thus oppose the Commission’s proposals.
Read full comments here.
