Date: February 4, 2015

Issue: Capital Standards

To: U.S. Securities and Exchange Commission

Filing Type: Regulatory

Description: CCMC's concern regarding the announcement on January 16, 2015, that the staff in the Division of Corporation Finance will express no views on the application of Rule 14a-8(i)(9) on any shareholder proposal during the 2015 proxy season. This announcement, a contradictory departure from a decision made just weeks earlier, benefits neither issuers nor investors and introduces an additional layer of uncertainty into an already complicated set of rules.

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