Society Comment Letters

• The Society's comment letter to the PCAOB in response to Release No. 2010-001 "Proposed Auditing Standard Related to Communications with Audit Committees and Related Amendments to Certain PCAOB Auditing Standards"

• The Society's comment letter to the SEC of January 19, 2010 Regarding Facilitating Shareholder Director Nominations (File No. S7-10-09)

• The Society's comment letter to the SEC of November 20, 2009 Regarding Ammendments to Rules Requiring Internet Availability of Proxy Materials

• The Society's comment letter to NASDAQ of November 2, 2009 Regarding Solicitation of Comments by the NASDAQ Listing and Hearing Review Council About Corporate Governance "Best Practices"
  

• The Society's comment letter to the SEC of September 15, 2009 Regarding Proxy Disclosure and Solicitation Enhancements (File Reference No. S7-13-09)
  

• The Society's comment letter to the SEC of August 13, 2009 Regarding Facilitating Shareholder Director Nominations (File No. S7-10-09)

• The Society's comment letter to the SEC of March 20, 2009 Regarding Proposed Amendment to New York Stock Exchange Rule 452 (Release No. 34-59464; File No. SR-NYSE-2006-92)
  

• The Society Subcommittee on Third-Party Advisory Services Comments to RiskMetrics Group ("RMG") 2009 Draft Voting Policies on November 4, 2008
  

• The Society's comment letter to the Voting Integrity White Paper from the Millstein Center of November 14, 2008

• The Society's comment letter to the FASB of August 4, 2008 regarding proposed modification to FAS 5 that would dramatically expand the type of disclosure that public companies are required to make about their loss contingencies
  

• The Society's comment letter to the SEC of August 1, 2008 regarding Proposed Rule on Interactive Data To Improve Financial Reporting (XBRL), File Number S7-11-08
  

• The Society's comment letter to the SEC re. Request for Interpretive letter Regarding Reporting under Section 16(a) of the Securities Act of 1934
  

• Society's comment letter to the SEC on its proposal relating to electronic filing and simplification of Form D (SEC Release Nos. 33-8814; 34-55980; 39-2446; IC-27878, 72 Fed. Reg. 37376 (July 9, 2007)) - File No. S7-12-07
  

• Society's comment letter of October 5, 2007 to the SEC Regarding Shareholder Proposals, Release Nos. 34-56160; IC-27913, File No. S7-16-07 and Comments on Shareholder Proposals Relating to the Election of Directors, Release Nos. 34-56161; IC-27915, File No. S7-17-07
  

• Society's comment letter to the SEC Regarding Smaller Reporting Company Regulatory Relief and Simplifications, Release Nos. 33-8819; 34-56013; 39-2447, File No. S-7-15-07; and comments on Revisions to the Eligibility Requirements for Primary Securities Offerings on Forms S-3 and F-3, Release No. 33-8812, File No. S-7-10-07
  

• The Society's comment letter to the SEC Regarding Proposed Revisions to Rule 144 and Rule 145 to Shorten Holding Period for Affiliates and Non-Affiliates, Release No. 33-8813, File No. S7-11-07
  

• The Society's comment letter to the SEC Regarding Definition of a Significant Deficiency, File No. S7-24-06
  

• The Society's Comment Letter to The SEC - Roundtables Regarding Stockholder Rights and the Federal Proxy Rules Proxy Voting Issues: Voting Integrity, File No. 4-537

  • Transcript of the Roundtable on the Federal Proxy Rules and State Corporation Law held on May 7, 2007 - on SEC website
    

• The Society's Comment Letter of March 25, 2007 to the SEC - Regarding Universal Internet Availability of Proxy Materials; File No. S7-03-07; Release Nos. 34-55147; IC-27672
  

• The Society's Comment Letter to PCAOB Regarding Proposed Auditing Standard — An Audit of Internal Control over Financial Reporting that is Integrated with an Audit of Financial Statements — and Related Other Proposals, PCAOB Rulemaking Docket Matter No. 21

  • PCAOB Adopts Auditing Standard No. 5 on PCAOB website
  • SEC Press Release - SEC Approves PCAOB Auditing Standard No, 5 on SEC website
    
    

• Society's comment letter of December 14, 2006 to the New York Stock Exchange Group Re: Support the concept of Client Directed Voting ("CDV")
  

• The Society's Comment Letter of December 4, 2006 to the SEC - Regarding the Rule 14a-8 Agenda Item for the SEC's December 13, 2006 Open Meeting
  

• Society's comment letter of September 18, 2006 to the SEC - Concept Release Concerning Management's Reports on Internal Control Over Financial Reporting, File Number S7-11-06.
  

• Society's comment letter of April 6, 2006 to the SEC regarding Executive Compensation and Related Party Disclosure; Release Nos.: 33-8655; 34-53185; IC-27218, File No. S7-03-06.
  

• Comment letter to the SEC Regarding Modify the cure Period Available to an Issuer that Loses File Number SR-NASDAQ-2006-011
  

• The Society's Comment Letter in Response to the Recommendations of the Proxy Working Group
  

• Comment Letter to the SEC Regarding Exposure Draft of Final Report of Advisory Committee on smaller Public Companies, Release Nos. 33-8666; 34:53385; File No. 265-23.
  

• Comment letter to the SEC Regarding Amendments to the Tender Offer Best-Price Rule, Release Nos. 34-52968; IC27193, File No. S7-11-05.
  

• Comment letter to the Public Company Accounting Oversight Board Relating to our Proposed Changes to Auditing Standard No. 2
  

• Comment letter to the SEC Regarding Internet Availability of Proxy Materials, Release Nos. 34-52926; IC-27182, File No. S7-10-05.

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• Comment letter to the SEC Regarding Public Company Accounting Oversight Board; Notice of Filing of Proposed Rule on Auditing Standard No. 4, Reporting on Whether a Previously Reported Material Weakness Continues to Exist
  

• Comment letter to the Financial Accounting Standards Board regarding the FASB staff's recent advice to one or more of the "big four" accounting firms that the grant date for financial measurement purposes under FAS 123(R) does not occur until the terms of the grant have been communicated to the employee.
  

  • Comment letter to the Financial Accounting Standards Board - Proposed Position
    

• Comment Letter to Justice E. Norman Veasey, Chair, Committee on Corporate Laws, Regarding the "Discussion Paper on Voting by Shareholders for the Election of Directors" Published by the Committee on Corporate Laws of the Section of Business Law of the ABA
  

• Comment letter to the SEC regarding Coalition Views on Shareholder Communications on behalf of the Business Roundtable, NIRI, STA and The Society, SEC File Number 4-493
  

• Comment letter to the SEC regarding Agenda of the Advisory Committee on Smaller Public Companies, Release Nos. 33-8751; 34-51610; File No. 265-23
  

• Comment letter to the SEC regarding Definition of Nationally Recognized Statistical Rating Release Nos. 33-8570; 34-51572
  

• Comment letter to NASDAQ relating to the possibility of the adoption of DRS (Direct Registration System) eligibility as a listing requirement, Concept Release on Securities and Transaction Settlement, Securities Exchange Act Release No. 49405 (March 11, 2004)
  

• Comment letter to the SEC regarding Securities Offering Reform, Releases Nos. 33-8501; 34-506249; IC-26649, File No. S7-38-04
  

• Comment letter to the SEC regarding Enhancing Commission Filings Through the Use of Tagged Data, Release Nos. 33-8497; 34-50454; 35-27895; 39-2429; IC-26623, File No. S7-36-04
  

• Comment Letter to the SEC regarding Temporary Postponement of the Final Phase-In Period for Acceleration of Periodic Report Filing Dates
  

• Comment letter to he SEC regarding the Commission's 2004-2009 Strategic Plan
  

• Comment Letter to the SEC regarding Ownership Reports and Trading by Officers, Directors and Principal Security Holders, Release Nos. 34-49895; 35-27861; IC-26471; File No. S7-27-04
  

• Comment letter to the SEC regarding Proposed Rule: Asset Backed-Securities, Release Nos. 33-8419; 34-49644; File No. S7-21-04
  

• Comment letter to the SEC regarding Mandated Electronic Form ID, Release Nos. 33-8399; 34-4916; 35-27815; 39-2416; IC-26385; File Number S7-14-04

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• Comment letter to the SEC regarding Security Holder Director Nominations, Release Nos. 34-48626; IC-26206; No. S7-19-03; RIN 3235-A193

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• Comment letter to the U.S. Postal Service regarding Eligibility Requirements for Standard Mail
  

• Comment letter to the SEC regarding Use of Form S-8 and Form 8-K by Shell Companies, Release Nos. 33-8407; 34-49566; File No. S7-19-04; RIN 3235-AH88
  

• Comment letter to the SEC regarding Concept Release: Securities and Transactions Settlement, Release Nos. 33-8398; 34-49405; IC-263846; File No. S7-13-04; RIN 3232-AJ19
  

More Comment Letters can be found in Core Documents