Date: November 5, 2013

Issue:  Proxy Advisory Firms

To: Institutional Shareholder Services

Filing Type: Regulatory 

Description:  CCMC submitted comments to ISS regarding its 2014 benchmark proxy voting guidelines. The letter reiterates our general concerns with the proxy advisory industry and makes specific comments on the proposed policies including a board’s response to majority-supported shareholder proposals and pay for performance quantitative screens.

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