Legislative & regulatory letters
Corporate governance means being good stewards of our beneficiaries’ capital-protecting and growing our investments.
In addition to engaging companies, we comment on regulatory policy and legislation.
We advocate for rules and regulations promoting good governance and improving transparency and safety of the market.
We advocate for state, federal and global legislation by working closely with regulatory and advisory industry bodies on updates in the governance arena to improve disclosures and raise governance standards.
We also work to oppose regulation and legislation that would weaken our rights as shareholders.
Regulatory letters
Date | Addressed to | Subject (Click to download) |
|---|---|---|
March 21, 2025 | Liane Randolph, Chair, California Air Resources Board | Public Comments to California Climate-Disclosure Information Solicitation |
March 19, 2025 | The Institute of Certified Public Accountants of Rwanda (ICPAR) | |
January 14, 2025 | United States Department of Labor Occupational Safety and Health Administration |
Regulatory letters
Date | Addressed to | Subject (Click to download) |
|---|---|---|
August 21, 2024 | Korea Sustainability Standards Board | |
July 31, 2024 | Sustainability Standards Board of Japan | |
June 24, 2024 | Ministry of Finance of China |
Regulatory letters
Date | Addressed to | Subject (Click to download) |
|---|---|---|
October 2, 2023 | U.S. Environmental Protection Agency | |
September 1, 2023 | Emmanuel Faber, Chair, International Sustainability Standards Board (ISSB) | |
August 22, 2023 | Public Company Accounting Oversight Board (PCAOB) | Public Input on Auditing Standards for Company Noncompliance with Laws and Regulations |
August 4, 2023 | U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA) | Public Input on Auditing Standards for Company Noncompliance with Laws and Regulations |
April 19, 2023 | Federal Trade Commission | |
February 14, 2023 | Public Company Accounting Oversight Board (PCAOB) | Public Input on Proposed Rule Governing An Audit Firm's System of Quality Control |
February 3, 2023 | Administrator Michael S. Regan (U.S. EPA) |
Regulatory letters
Date | Addressed to | Subject (Click to download) |
|---|---|---|
July 29, 2022 | Emmanuel Faber, Chair, International Sustainability Standards Board (ISSB) |
U.S. Securities and Exchange Commission letters
Date | Addressed to | Subject (Click to download) |
|---|---|---|
June 17, 2022 | Vanessa A. Countryman, Secretary | The Enhancement and Standardization of Climate-Related Disclosures for Investors |
March 2, 2022 | Vanessa A. Countryman, Secretary |
Legislative letters
Date | Addressed to | Subject (Click to download) |
|---|---|---|
October 5, 2021 | Rep. Maxine Waters and Rep. Patrick T. McHenry |
Regulatory letters
Date | Addressed to | Subject (Click to download) |
|---|---|---|
September 8, 2021 | Bureau of Alcohol, Tobacco, Firearms, and Explosives | |
September 3, 2021 | CFA Institute | |
August 18, 2021 | Bureau of Alcohol, Tobacco, Firearms, and Explosives | |
July 29, 2021 | Erkki Liikanen, Chair, International Financial Reporting Standards (IFRS) Foundation | Constitutional Amendments to Establish an International Sustainability Standards Board (ISSB) |
July 12, 2021 | Public Company Accounting Oversight Board (PCAOB) |
U.S. Securities and Exchange Commission letters
Date | Addressed to | Subject (Click to download) |
|---|---|---|
June 4, 2021 | Gary Gensler, Chair |
Regulatory letters
Date | Addressed to | Subject |
|---|---|---|
December 22, 2020 | Erkki Liikanen, Chair International Financial Reporting Standards (IFRS) Foundation | Sustainability Reporting – Establishing a Sustainability Standards Board |
October 5, 2020 | Employee Benefits Security Administration | Fiduciary Duties Regarding Proxy Voting and Shareholder Rights |
September 28, 2020 | The Financial Conduct Authority | |
September 5, 2020 | Ontario Capital Markets Modernization Task Force | Sign-On Letter - Improving Issuers' ESG Performance & the Regulatory Structures |
September 1, 2020 | European Supervisory Authorities (ESA) | European Supervisory Authorities Joint Consultation on ESG Disclosures |
July 30, 2020 | U.S. Department of Labor, Jeanne Klinefelter Wilson, Assistant Secretary | |
July 21, 2020 | Federal Reserve System, Honorable Jerome H. “Jay” Powell, Chairman, Board of Governors | Sign-on Letter Regarding Financial Regulators for Action on Climate Risk |
U.S. Securities and Exchange Commission letters
Date | Addressed to | Subject |
|---|---|---|
December 23, 2020 | Vanessa A. Countryman, Secretary | Adopt Nasdaq Stock Exchange Board Diversity Listing Standards |
August 21, 2020 | Chairman Clayton and Secretary Countryman | Modernization of Regulation S-K Items 101, 103 and 105 - Follow-Up Letter |
February 3, 2020 | Securities and Exchange Commission – Vanessa A Countryman, Secretary | Proposed Rules on Proxy Advisors and Shareholder Proposal Submission Thresholds |