The ISS Global Policy Board recently solicited comments with respect to its proposed updates to its benchmark proxy voting guidelines. One of the policy changes under consideration relates to corporate political spending disclosure proposals. Under ISS’ current guidelines, these proposals are evaluated on a case-by-case basis. ISS is now proposing to change its position to a “generally vote FOR recommendation”.

This week, 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 the change. ISS’ proposed change is unwarranted for a number of reasons, including...