Date: October 28, 2014
Issue: 2015 Benchmark Policy Consultation
Filing Type: Regulatory
Description: The CCMC is concerned that the “Policy Consultation” is not really a consultation at all—it was published on October 15, 2014, but requires a response no later than 6 pm on October 29, 2014. The issues raised vis-à-vis U.S.-domiciled companies are complex, and ISS’ abbreviated descriptions of them do not lend them to instant analysis, given the abbreviated time frame provided. Utilizing a time frame this compact strongly suggests the outcome of this “Consultation” is already known, and that the “Consultation” reflects a decision in search of a process.