Comments on Proposed Rule: Disclosure of Hedging by Employees, Officers and Directors

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Date Received
Date Letter Type Commenter Name
Meeting with SEC Officials Memorandum from the Office of Commissioner Kara M. Stein regarding a May 10, 2018, meeting with representatives of Americans for Financial Reform, Public Citizen, the American Federation of State, County and Municipal Employees and the AFL-CIO
Meeting with SEC Officials Memorandum from the Division of Corporation Finance regarding a January 4, 2018, meeting with representatives of the Center on Executive Compensation
Public Comment Jeffrey P. Mahoney, General Counsel, Council of Institutional Investors
Public Comment David M. Lynn, Chair, Federal Regulation of Securities Committee, Business Law Section, American Bar Association
Public Comment Catherine T. Dixon, Chair, Federal Regulation of Securities Committee, Business Law Section, American Bar Association
Public Comment Susie E. Hawthorne, Missoula, Montana
Public Comment Keith P. Bishop, Former California Commissioner of Corporations, Irvine, California
Public Comment John Hayes, President and Chief Executive Officer, Ball Corporation and Chair, Corporate Governance Committee, Business Roundtable, Washington, District of Columbia
Public Comment McDermott Will & Emery LLP
Public Comment Michael P. McCauley, Senior Officer, Investment Programs and Governance, Florida State Board of Administration, Tallahassee, Florida
Public Comment David B. Smith, Jr., Executive Vice President and General Counsel, Mutual Fund Directors Forum, Washington, District of Columbia
Public Comment Davis Polk & Wardwell LLP
Public Comment Dorothy Donohue, Deputy General Counsel, Securities Regulation, Investment Company Institute
Public Comment Joyce Dillard
Public Comment Kurt N. Schacht, CFA, Managing Director, Standards and Financial Market Integrity, and Linda L. Rittenhouse, Director, Capital Markets Policy, CFA Institute
Public Comment Public Citizen
Public Comment Rick E. Hansen, Assistant Secretary and Managing Counsel, Society of Corporate Secretaries and Governance Professionals
Public Comment Tim Goodman, Head of US Engagement, Hermes Investment Management
Public Comment Clinton Carlisle, Student, University of Colorado Law, Boulder, Colorado
Public Comment Chris Barnard, Germany
Public Comment Cleary Gottlieb Steen & Hamilton LLP
Public Comment Jeff Mahoney, General Counsel, Council of Institutional Investors
Public Comment Michael Nau, Ph.D. Candidate, Ohio State University Department of Sociology
Public Comment John A. Olagues, River Ridge, Louisiana
Public Comment Taylor Dove
Public Comment Timothy R. Wing, MST, President & CEO, STock/Option Consulting & Knowledge Services, Inc.

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-01-15
Release Number
33-9723
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