Proxy Solicitation and Investor Relations Firms
"What is needed is a system that creates a true register of owners able to vote at a meeting rather than perpetuate a system that no longer reflects the standard that other global markets are moving to in terms of establishing the identity of owners eligible to vote at a meeting." Kenneth Altman, The Altman Group, SEC Comment Letter, May 23, 2007, SEC File No. 4-537.
"[P]roviding issuers with direct access to their beneficial owners and allowing issuers to designate their own agent or agents for delivering proxies and tabulating votes, would not only avoid the confusion and inefficiencies associated with intermediaries delivering their own Notices of Internet Availability and requests for voting instructions, but could also mitigate or even completely alleviate any over-voting issues. Mellon urges the Commission to address these matters as a whole." Stephen Dolmatch and William Harris, Mellon Investor Services, SEC Comment Letter, February 13, 2006, SEC File No. S7-10-05.
"[I]f we are to take full advantage of modern technologies - AND fully realize the major savings that issuing companies and their shareholders will realize if technological changes are properly implemented - the free market system must be allowed to operate in the American way: A fresh and top-to-bottom look at the current proxy delivery process - including a fresh and open bidding process, for tasks that have not been competitively bid-out in 20 years - is absolutely essential." Carl Hagberg, The Shareholder Service Optimizer, SEC Comment Letter, February 13, 2006, SEC File No. S7-10-05.
"Companies simply need to know who all their shareholders are, when shareholders buy and sell shares, and how they can communicate with all shareholders. ... On behalf of the companies we serve, Shareholder.com urges the Commission to revamp the industry's approach to shareholder identification and communication." Ronald Gruner, Shareholder.com, SEC Comment Letter, February 1, 2005, SEC File No. 4-493.
"We urge the Commission to conduct a review of proxy voting mechanics and back office procedures for the purpose of reducing complexity, increasing transparency, eliminating inefficiencies, and lowering costs, thereby improving corporate governance and enhancing the rights of both shareholders and issuers under the proxy rules." John Wilcox, Georgeson Shareholder Communications, SEC Comment Letter, April 12, 2004, SEC File No. S7-19-03.
"We recommend that the Commission look for ways to simplify the complex infrastructure of proxy communications. Direct access to street name accounts would allow companies to bypass intermediary layers and communicate directly with beneficial owners or their designated decision-makers. In addition to eliminating procedural steps and reducing costs, direct access would permit greater use of electronic technology to streamline the transmission of disclosure documents and voting instructions." John Wilcox, Georgeson Shareholder Communications, SEC Comment Letter, May 22, 2003, SEC File No. S7-10-03.
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