Church Investment Group president JoAnn Hanson has written to Vanessa Countryman, secretary of the Securities and Exchange Commission to express strong support for the proposed rule changes to the three bases for exclusion in the Commission’s Rule 14a-8 proposed in Exchange Act Release No. 95267, “Substantial Implementation, Duplication, and Resubmission of Shareholder Proposals Under Exchange Act Rule 14a-8”.
She states, “We urge the Commission to adopt the Proposed Changes because they would:
- Increase the quality of communication between shareholders and boards/management and among shareholders;
- Reflect the dynamic nature of the shareholder proposal process by allowing proponents to refine proposal strategies over time;
- Enable shareholders to vote on different approaches to address critical issues;
- Better enable shareholders to address systemic, portfolio-wide risks with companies; and
- Make the no-action process more predictable and more efficient.”