The comment period on the SEC’s proposal to amend Items 101, 103 & 105 of Regulation S-K recently expired. In the proposing release, the SEC laid out some controversial changes to current rules, including a “principles based” approach to Item 101 & a “human capital resources” disclosure requirement. In light of the contentious nature of these proposals, I thought a stroll through the comment letters might be interesting – and I was right.
First off, there was the uncanny fact that 2,829 people submitted the exact same comment letter. Cynics may suggest that this is the result of an astroturf campaign, but I think that it’s likely just an example of Carl Jung’s theory of the collective unconscious in action. Of course, all of the usual suspects also weighed in with their comments. Big Business, Big Law, Big Investor & Big Labor were all well represented.
But so was a new entrant into the governance debate – I guess I’ll call this one “Big Yoga“. “Yoga Burn Challenge” CEO Zoe Bray-Cotton submitted a comment letter focusing on human capital issues. Her comments are thoughtful & serve as a reminder that these issues matter to a broader segment of society than just those of us who earn a living dealing with securities regulation. But what really made her letter stand out from the crowd was the fact that she cited us – well, actually, ME! – in it:
I also refer to the following articles published by TheCorporateCounsel.net website:
- Board Gender Diversity: Good for Business
- Gender Quotas on Boards?
- “Just Vote No”: State Street’s Alternative to Quotas
Those were all in a blog that I wrote a couple of years ago. Anyway, she plugged me, so I will plug her. Go check out the Yoga Burn Challenge – and tell Ms. Bray-Cotton that I sent you.
-John Jenkins, TheCorporateCounsel.net November 7, 2019
