Date: February 18, 2015

Issue: Proxy Advisory Firms

To: The Honorable Mary Jo White, Chair, SEC 

Filing Type: Regulatory 

Description: The CCMC is concerned that a universal ballot is a vehicle to fix the unbroken.
Consequently, the universal ballot will divorce corporate governance from the fiduciary duties integral to the long-term performance of a public company and its ability to provide a return to investors. Director elections will turn into annual political-style campaigns and create dynamics that are not conducive to the effective management of a public company.

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