Comments on Proposed Rule: Shareholder Proposals

Comments have been received from individuals and entities using a variety of Letter Types:


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Date Received
Date Sort descending Letter Type Commenter Name
Public Comment James J. Angel, Ph.D., CFA, Georgetown University, Associate Professor of Finance, McDonough School of Business
Public Comment John Chevedden
Public Comment Jon M. Jensen, Executive Director, The Park Foundation, Ithaca, New York
Public Comment Jose Quirarte
Public Comment Judith S. Scott, Executive Vice President and General Counsel, Portfolio Recovery Associates
Public Comment Julia M. Schweri
Public Comment Karrie McMillan, General Counsel, Investment Company Institute
Public Comment Keith F. Higgins, Committee Chair Committee on Federal Regulation of Securities of the American Bar Association, Section of Business Law
Public Comment Kurt N. Schacht, JD, CFA, Managing Director, CFA Institute Centre for Financial Market Integrity and Linda L. Rittenhouse, JD, Senior Policy Analyst, CFA Institute Centre for Financial Market Integrity
Public Comment Laurel A. Holschuh, Assistant General Counsel and Secretary, Wells Fargo & Company
Public Comment Lauren Compere, Director of Shareholder Advocacy, Boston Common Asset Management, LLC
Public Comment Liz Murral, Senior Adviser Corporate Governance, Investment Management Association
Public Comment Lucian A Bebchuk, Professor, Harvard Law School, on behalf of a Group of Thirty-Nine Law Professors in Favor of Placing Shareholder-Proposed Bylaw Amendments on the Corporate Ballot
Public Comment Lydia I. Beebe, Corporate Secretary and Chief Governance Officer, Corporate Governance, Chevron Corporation
Public Comment Michael O'Sullivan, President, Australian Council of Super-Investors; Steve Gibbs, Chief Executive Officer, Australian Reward Investment Alliance - Australia; Ian Jones, Head of Responsible Investment, Co-operative Insurance Society - UK; Councillor Darrell Pulk, Chair of the Forum, Local Authority Pension Fund Forum - UK; Anita Skipper, Head of Corporate Governance, Morley Fund Management Limited - UK; Arno Kitts, Chairman of the Investment Council, National Association of Pension Funds - UK; Frank Curtiss, Head of Corporate Governance, RAILPEN Investments - UK; Giles Craven, General Manager, Trustee Services Unit, Shell International Limited - UK; and Peter Moon, Chief Investment Officer, Universities Superannuation Scheme - UK
Public Comment Michelle Edkins, Acting Chairman, ICGN Shareholder Rights Committee
Public Comment Paul M. Neuhauser
Public Comment Peter D. Kinder, President, KLD Research & Analytics, Inc.
Public Comment Peter Montagnon, Director of Investment Affairs, Association of British Insurers
Public Comment Raymond C. Offenheiser, President, Oxfam America, Boston, Massachusetts
Public Comment Renee Roberts
Public Comment Richard H. Moore, Treasurer, State of North Carolina
Public Comment Richard J. Daly, CEO, Broadridge Financial Solutions
Public Comment Richard W. Torgerson, Director, Social Research & Shareholder Advocacy, Progressive Asset Management
Public Comment Robert M. Stanton, Pittsburg, Pennsylvania
Public Comment Sharon A. Haeger, Americas Community Bankers and Sarah A. Miller, General Counsel, ABA Securities Association
Public Comment Steve Odland, Chaiman & CEO, Office Depot, Inc.
Public Comment Sullivan & Cromwell LLP
Public Comment Thomas J. Wilson, President and Chief Executive Officer, The Allstate Corporation, Northbrook, Illinois
Public Comment Thomas M. Sullivan, Chief Counsel of Advocacy, and Janis C. Reyes, Assistant Chief Counsel, SBA Office of Advocacy

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-16-07
Release Number
34-56160
IC-27913