Corporate Governance Regulation - Proxy Access - Financial Services Roundtable - November 18, 2010

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Dodd-Frank Timeline, Proxy Access, SEC
Comment Deadline Final Rule Issue Effective Date
February 16, 2010 September 20, 2011 September 20, 2011 VACATED BY COURT ORDER

Reporting of Proxy Votes on Executive Compensation
November 18, 2010

The Financial Services Roundtable states that the SEC should not use specific language for a proxy vote or use such a prescriptive approach in framing the shareholder vote on executive compensation. The letter explains that the Commission's rules surrounding which issuer shares that are entitled to a say-on-pay vote and the frequency of that vote have become to specific. Rather, state law should apply in the majority of these cases, and the Commission's rules should state this.


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