Atkins warns that regulation encrusts equity markets, requiring caution when removing rules to avoid harm.
“Because regulation encrusts the equity markets, we must be exceedingly careful to avoid doing more harm than good when we seek to break off a piece of that crust.”
Atkins concludes SEC staff interposition between companies and shareholder proponents is unnecessary for resolving proposal inclusion.
“But my greatest takeaway is that the Commission staff’s interposition between companies and shareholder proponents is unnecessary to effectively and efficiently resolve whether shareholder proposals should be included in proxy statements.”