The SEC's proxy process review has so far led the SEC to approve two separate releases regarding proxy advisors. The focus of this comment letter is on the guidance provided in one of those releases, Release No. IA-5325 (Release). This guidance identifies, under the Investment Advisers Act of...

Please find attached the slides I presented at the George A. Leet Symposium on Nov. 6, 2020. I am going to be revising my white paper, "The Conflict between Blackrock's Shareholder Activism and ERISA's Fiduciary Duties" based on these slides. This revised version will then be published in the...

The focus of this Article is on the agency costs that may be created by the empty voting of investment advisers to index funds and how they can be mitigated so as to protect the value of private employee pension benefit plans. This Article focuses on BlackRock because it has taken a leadership...