Section 951 of the Dodd-Frank Act requires companies that are subject to the SEC’s proxy rules to include in their proxy statements “a separate resolution subject to shareholder vote” to determine whether a shareholder vote on executive compensation will occur every 1, 2, or 3 years. When the SEC was considering amendments to its rules to implement this requirement, I argued that corporations should be free to use other voting rules such as a Borda count or preference ranking system. See “Counting The Vote When There Are Three Choices“. Although the SEC noted my comment (and a similar comment from the Society of Corporate Secretaries and Governance Professionals) in its adopting release, the SEC declined to take up the suggestion.