Last November, I joined Professor Stephen Bainbridge (UCLA Law School) and James Copland (Director, Center for Legal Policy at the Manhattan Institute) in submitting this comment letter opposing ISS’ proposal to change its case-by-case approach to stockholder proposals with respect to disclosure of corporate political spending. Much like Captain Louis Renault, I was “shocked, shocked” when ISS ignored our advice and decided that it would generally recommend a “for” vote for these proposals.

Having decided on a one-size-fits all approach, ISS recently announced that it will be hosting a webinar next week on political spending proposals. In this case, I was truly surprised at the lineup that ISS chose for this topic...