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Side Letter Governance

Harvard Corporate Governance

Over time, however, this simple and uniform structure has become far more complex: sponsors routinely enter into separate agreements (or “side letters”) with some or all of their investors, under which each investor in question is granted a tailored set of additional rights. more…)

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Larry Fink’s Annual Letters to Investors

Harvard Corporate Governance

For more than ten years, Larry Fink, Chairman and CEO of BlackRock, the world’s largest asset manager, has published separate annual letters — one to CEOs and another to BlackRock’s shareholders.

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The SEC Revolving Door and Comment Letters

Harvard Corporate Governance

In our study, forthcoming at the Journal of Accountancy and Public Policy and available at SSRN , we examine the impact of the revolving door on the SEC’s comment letter process, a crucial process by which the SEC exercises its regulatory mission.

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2023 Annual Letter to Boards

Harvard Corporate Governance

Against a backdrop of challenging macroeconomic forces, our 2023 annual letter to boards is one that emphasizes understanding and preparing for the additional hurdles that will compound and be compounded by these macroeconomic forces. This post is based on her Freshfields piece. Introduction.

Banking 255
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Jamie Dimon’s Chairman & CEO Letter to Shareholders

Harvard Corporate Governance

This post is based on his discussion of the subjects of banking turmoil and regulatory goals in his recent Chairman & CEO Letter to Shareholders. As I write this letter, the current crisis is not yet over, and even when it is behind us, there will be repercussions from it for years to come.

Banking 234
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What the Volume and Diversity of Comment Letters to the SEC Say About its Climate Proposal

Harvard Corporate Governance

The SEC has posted some 14,000 letters it received: These letters come from an astounding array of people and organizations, a far larger and diverse group than SEC rule proposals usually attract. neither drew as many tailored letters as the climate rule (those drew ~1500 and ~3400 respectively).

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SEC Comment Letter on Share Repurchase Disclosure Modernization

Harvard Corporate Governance

Pay Governance recently submitted a comment letter to the U.S. In our comment letter we acknowledge not being experts on share repurchase disclosure, but we wanted to address aspects of the SEC’s business case for the proposed changes. Introduction and Background.

Equity 207