A Plumber's View - Voting Intermediated Shares


Introduction

“The existing system of shareholder voting is crude, imprecise, and fragile. Gil Sparks, a leading Delaware lawyer, estimates that, in a contest that is closer than 55 to 45%, there is no verifiable answer to the question ‘who won?’”[1]

That system, explicated by Kahan and Rock in 2008, is largely the same system employed today. This post updates the seminal work of Kahan and Rock, from whom the quote came, by (1) briefly reviewing how shareholder voting in the United States is crude, imprecise, and fragile,[2] (2) comparing the U.S. system to other shareholder voting systems around the world to highlight practices that are more precise and robust, (3) discussing technology that can increase the certainty and validity of shareholder votes, and (4) suggesting regulatory reforms that might alleviate some voting problems.

U.S. Proxy Voting

This section reviews how shareholder voting in the United States is dysfunctional. It starts by presenting background necessary to understand the shortcomings in shareholder voting: how stock is held, the law of share ownership and voting, and the basic mechanics of a shareholder vote. The section then turns to three types of problems that arise in shareholder voting: those that arise from systemic complexity, from questions of ownership, and from divergence between economic interests and voting rights.

How Stock is Held – Intermediated Shareholding

Intermediated shareholding refers to a chain of property rights in corporate shares, extending from the Depository Trust and Clearing Corporation (“DTCC” or “DTC”) and its subsidiary Cede & Co. (“Cede”), through DTCC’s members and those members’ respondent banks,[3] ultimately to beneficial shareholders, who are commonly thought of as a publicly-listed company’s stockholders. Nearly all shares are owned through this intermediated structure. DTCC’s annual reports from 2009 and 2017 provide the total value of active securities issues held at DTCC as $40 trillion and $57 trillion, respectively.[4] These values account for most of the total market capitalization of listed domestic companies in the entire world, reported by the World Bank as $44.6 trillion in 2009 and $79.2 trillion in 2017.[5]

Intermediated shareholding took root from the “paper crush” of the 1960s. At that time, share ownership was evidenced by physical, paper stock certificates, and when parties bought or sold shares, the certificates were delivered to the buyer’s broker and the buyer was then registered on the corporation’s shareholder list.[6] This paper-intensive process lasted until the 1970s, by which time the flood of daily paper, administrative errors, and inability to keep up with transactions bankrupted brokers and consistently closed markets.[7]

The solution to that labor intensive, time consuming, and error fraught process came in the form of a central clearing party called DTCC and its subsidiary Cede. As a result, share certificates were generally held permanently in a DTCC vault or in DTCC’s electronic records (commonly referred to as being immobilized) and registered in the name of Cede. Therefore, Cede “is listed as the record holder for a vast majority of stock.”[8] However, while Cede holds the shares and is the registered shareholder of record on the company’s shareholder ledger, property law has developed, and contractual arrangements have been established, so that the economic and legal benefits of shareholding flow through to the underlying investors of the shares, referred to as “beneficial owners.” Therefore, Cede does not enjoy the economic benefits of a shareholder from its registration as a shareholder.

Beneficial shareholders, also known as “entitlement holders,” have accounts with banks, brokers, and other institutions (“custodians” or “securities intermediaries”). Those custodians provide “asset safekeeping, trade processing and settlement” services for their accountholders.[9] Some custodians have accounts directly with DTCC. When a beneficial shareholder places a trade with a counterparty at a different custodian, and both custodians have accounts with DTCC, two things happen. First, the accounts of each trading party are changed on the custodians’ books. For example, if retail investor Joe owns 500 shares of Delaware Inc. stock in his account at Broker A and he sells his 500 shares and the counterparty is retail investor Jane who has an account at Broker B and who previously owned no Delaware Inc. shares, Broker A will change its records to show that Joe now owns zero Delaware Inc. shares and Broker B will change its books to show that Jane owns 500 shares. Second, DTCC registers the change in shareholding on its books to reflect the shares held in the accounts of Brokers A and B.[10] Assuming no other shares in Delaware Inc. were traded at Broker A or B, DTCC’s books would reflect a 500 share reduction in Delaware Inc. shares held in Broker A’s account and an increase of 500 shares in Broker B’s account. The simplest case, when a beneficial shareholder places a trade with a counterparty at the same custodian (i.e., the same broker), that custodian will enter the proper book-entries for its customers, and nothing changes at DTCC or on the books of any other custodian.

Importantly, not all custodians have accounts with DTCC and they must then use a custodian, or a chain of custodians, who does have an account at DTCC to book the transaction. Therefore, a beneficial shareholder might be two or three custodians removed from a DTCC member. Any intermediary between DTCC and beneficial shareholders track changes in stock ownership with new book entries, which flow up and down the chain of intermediaries as needed. A simplified version of this chain of intermediated shareholding is illustrated below:[11]




Muddled Legal Landscape – UCC, State Corporation Law, and N(OBO)s

Property law developed in response to intermediated shareholding, ensuring that beneficial shareholders retain legally recognized economic interests in their accounts, despite the fact that Cede is the shareholder of record, and economic and legal rights pass through layers of intermediaries. Specifically, Uniform Commercial Code (“UCC”) Article 8 provides that beneficial shareholders enjoy a “securities entitlement”[12] in a “financial asset.”[13] The entitlement attaches as soon as the custodian “makes a book entry indicating that the customer has bought shares.”[14] Beneficial shareholders do not enjoy an interest in any particular share or other property, but rather “a pro rata interest in all like securities of the intermediary held in common by all other customers who own the same security.”[15] In sum, beneficial shareholders “jointly own an interest in a fungible mass, with no specific shares attributed to any specific customer.”[16] An example is helpful to illustrate how this works. If Broker A is recorded by DTCC as holding 100,000 shares of Delaware Inc. and Broker A’s records indicate that retail investor Joe’s account owns 1,000 shares of Delaware Inc., then Joe has a securities entitlement in 1% of the 100,000 shares held by Broker A.

While the UCC ensures that the beneficial owner has an economic interest in the shares he indirectly owns, state corporation law is not so sophisticated. In fact, state corporation law is “straightforward.”[17] Whoever is registered on the corporation’s stockholder record, i.e., Cede, is the legal owner of the shares and thus holds the legal rights to vote, receive a dividend, sue, et cetera. To confer these rights to the beneficial owner of the shares, DTC passes these onto DTC’s accountholders, and those accountholders in turn pass some or all of those rights on to their accountholders. Thus, with respect to shareholder voting, DTC acts as the agent of its accountholders who in turn act as the agent of their accountholders.  As a result, DTC passes voting rights to its participants, who then either pass voting rights along, or vote the shares based on instructions from their accountholders, who receive instructions from their accountholders. That chain continues until the beneficial shareholder is reached. To continue the example from the previous paragraph, DTC will pass its voting rights in Delaware Inc. stock to Broker A via an omnibus proxy. Broker A then sends Joe proxy materials and a voter information form (“VIF”) asking for his voting instructions, which Broker A will follow with respect to 1% of their vote, when Broker A submits its votes. If Broker A has a separate account for Broker B, who is not a DTCC participant but holds stock on behalf of 100 beneficial owners, Broker A will execute an omnibus proxy in Broker B’s favor, granting Broker B the right to vote those shares.

Therefore, as a state law corporate matter, “[e]ven if communication with [beneficial] owners could be simplified, solicitation of proxy or voting instructions still must pass through each intermediary: to be legally valid, the power of agency must bind each intermediary in an unbroken chain between the record owner[, Cede,] and the beneficial owner.”[18] State law has not changed in response to the immobilization and intermediation of shareholding.[19]

To complicate matters further, the Securities and Exchange Commission (“SEC”) allows beneficial owners, at the end of the daisy chain, to remain anonymous with respect to the issuer. The SEC categorizes beneficial shareholders into two buckets: Non-Objecting Beneficial Owners (“NOBOs”) and Objecting Beneficial Owners (“OBOs”). NOBOs are beneficial shareholders who allow their brokers or banks to disclose their identity to the issuer, while OBOs insist on anonymity vis-à-vis the issuer. NOBO is the default shareholder position.[20] About 75% of retail investors are NOBOs, while most institutional investors are OBOs.[21] As of 2004, 75% of all shares held in street name were OBOs, and that percentage is now likely higher.[22]

The interactions of federal securities law, state corporation law, UCC Article 8, and the custodian daisy chain, provides the backdrop to our “crude, imprecise, and fragile” voting system.[23]

Simple Mechanics of Corporate Voting

Under state corporate law, the corporation must “look in the stockholders list [(“record” or “ledger”)] for names and addresses, and second, send the materials to those persons at those addresses.”[24] Slightly more fully: “The corporation sends out proxy cards, a proxy statement, and the annual report to its registered owners. The registered owners execute the proxy to indicate how they wish to vote their shares. The proxies are then returned to a tabulator (also known as an “inspector of elections,” or “inspector”[25]) who, after checking their formal validity and comparing them to the share register, reports the outcome to the board of directors.”[26]

As noted earlier, intermediation creates a string of parties through whom voting communications must pass to reach beneficial shareholders, who ultimately have voting rights. “To eliminate the cost and delay that a series of one-to-one handoffs would entail, both issuers and intermediaries assign power of attorney to Broadridge Financial Solutions [(“Broadridge”)] to distribute disclosure information to beneficial owners and to collect their voting instructions.”[27] The systemic result of these delegations to Broadridge is represented below:[28]



Despite this seemingly efficient delegation to Broadridge, the system remains complex. Barrett provides a helpful overview of typical corporate elections.[29]

1.     When an issuer announces a corporate election, it must identify intermediaries holding its stock and ask them how many proxy material packages they require for beneficial owners.[30] This is an iterative process that may involve multiple layers of respondent banks and brokers.
2.     The issuer issues an “omnibus proxy,” which confers voting authority to securities intermediaries with respect to the shares in their DTC account on the record date. Brokers and banks transfer their proxy authority, through power of attorney, to Broadridge.
3.     The issuer sends proxy disclosure packets to Broadridge for distribution, on behalf of intermediaries, to beneficial owners. SEC regulations require that issuers reimburse intermediaries for the cost of distributing these materials.[31] Broadridge sends required disclosures concerning questions subject to a shareholder vote and a VIF. Beneficial shareholders receive a VIF, rather than a proxy card, when their custodian retains the legal right to vote shares or grant proxy authority and the beneficial shareholders only have the right to instruct the custodian.[32]
4.     The beneficial owner returns their VIF to Broadridge. The beneficial owner may change their voting instructions up until the time polls close, and the last-in-time instructions control.
5.     Broadridge tabulates incoming VIFs, reporting continuously updated results to intermediaries and the issuer. It is not customary for any party in this process to issue written confirmation of received VIFs.
6.     Securities intermediaries send Broadridge a proxy, or more often a series of incremental partial proxies, indicating aggregated shares voted for and against each proposal or director nominee. If the inspector of elections is a different entity than Broadridge, [33] Broadridge forwards the proxies collected in this way to the official inspector.[34]
7.     At this point, the steps in an uncontested and contested election diverge. Sub-(a) refers to uncontested elections while sub-(b) refers to contested elections.
a.     The tabulator forwards collected proxies to the shareholder meeting, with information about conflicting proxies, over-votes, and other problems.
b.     Each faction, having obtained its proxies from Broadridge, delivers them to the inspector, who takes them to a secure, neutral counting room. The counting of votes and appointment of an inspector is governed by state, not federal, law.[35]
8.     -------------------------
a.     The inspector oversees the validation and counting of proxies to verify legality of the election.
b.     Proxies from registered owners are segregated from intermediary proxies, and are sorted into the same order as the stockholder list. Each of the inspector’s assistants takes a group of proxies.
9.     -------------------------
a.     The inspector examines proxies, excluding those that were not properly executed. Since the outcome is predetermined, little effort is expended validating proxies.
b.     The inspector’s staff examines registered owners’ proxies and checks them against the stockholder list, sorting them into categories: for management, for opposition, conflicting, invalid (e.g., not on the list) and technically invalid (e.g., no signature). Proxy counting begins.
10.  -------------------------
a.     The inspector totals votes cast for the management slate of director candidates.
b.     The inspector’s staff attempts to resolve partial proxies and revocations for each intermediary, commonly asking for help from the intermediary itself. Proxy counting continues.
11.  The inspector totals the votes and certifies, in a report to the meeting chair, the number of shares present and the votes cast for and withheld from the proposals and candidates. Then, the meeting chair reports the vote count and announces the outcome – for instance, that there was a quorum, that certain candidates were elected, and that certain proposals were approved.

A stylized and simplified version of this process is drawn below:



Complexity Problems – Votes Not Cast, Not Counted, and Not Verified

The complexity of the voting system means that materials do not always arrive to beneficial shareholders on time or at all. Under Delaware law, shareholder votes must occur within 60 days of announcement of a shareholder meeting.[36] “For shares held in nominee name, the following steps must occur before the materials are mailed out: the issuer sends an inquiry to DTC; DTC responds; the issuer sends out search cards to the custodians; the custodians respond; often this process has to be repeated for multiple tiers of custodians; then, and only then, can the issuer mail the materials to Broadridge, which then distributes them to the shareholders.”[37]

Some votes that do or should arrive are not counted. Kahan and Rock document a vote by a 9% shareholder, who submitted their vote at 11:00 p.m. on the last voting day, only to later learn that the tabulator had stopped counting votes at 4:00 p.m. that day.[38] One year, Unilever failed to receive votes from three major institutional investors “because of a coding error by Institutional Shareholder Services,[39] which served as a voting agent for the institutional investors.

Missing and uncounted votes can wreak havoc on vote validity and outcomes. In 1993 Broadridge “experienced significant difficulties …, causing several firms to struggle to meet quorum requirements or to postpone meetings ….”[40] Uncounted votes can be either pro- or anti-management,[41] and either way they undermine confidence in the validity of final results.

Even if votes are cast and counted, their source often cannot be audited and verified. Any attempt at verification is difficult simply because the shareholder list used to count votes is just a compilation of the DTCC record, the issuer record, and the records of multiple layers of intermediaries.[42] The records are assembled, but “no effort is made to conduct an audit or reconcile inconsistent share positions.”[43] Moreover, official tabulators have little transparency into how “Broadridge and its customers–the bank and broker custodians–adjust overvotes, revocations, and other problems within its system ….”[44] And, “[e]ven less is known about how often Broadridge makes clerical errors in compiling its proxy based on the numerous voting instructions provided by beneficial holders or in verifying that the person giving the instructions had proper voting authority.”[45]

Verification problems also arise through the more granular complexity of how stock is held and voted. Many custodians hold stocks (1) directly, (2) through other custodians, and (3) for customers.[46] As noted above, they submit partial proxies to Broadridge, voting only some of their shares.[47] Custodians vote partial proxies because they do not always have voting instructions from all their accountholders, or the custodian may not yet know how they want to vote shares held in their own account. Custodians continue to submit partial proxies, cumulating their votes and splitting their position between “for,” “against,” and “abstain,” until they vote all the shares held in all different forms.[48] This voting method requires attention to ensure that the custodian does not submit too many votes, and some custodians inevitably over-vote their positions.[49] Many custodians submit votes in batches without any associated customer account numbers, making it impossible to verify whether the vote was for the custodian’s own account or for a beneficial shareholder, and if it was for a beneficial shareholder, which one provided the voting instruction.[50] Many respondent banks have one account with their custodians, even though the respondent bank represents many beneficial owners.[51] Therefore, even when the votes submitted to Broadridge have an account number associated with them, it can be difficult to trace the voting instructions back to beneficial owners through the multiple tiers of intermediaries.

Ownership Problems – Lending Surprise and Over-voting

Two voting issues arise when shareholders lend out their shares: lending surprise and over-voting.

Stock lending is when a shareholder transfers title in a share to a buyer, who agrees to sell it back to the shareholder at a later date. Buyers are often short-sellers, hoping to take the lent share, sell it in the market at a high price, and buy it back later at a lower price. Shareholders engage in lending because revenue from the securities lending fee and interest on the cash, which is reinvested while the share is on loan, is lucrative.[52] For example, CalPERS makes well over $100 million annually through securities lending.[53] Investors like CalPERS typically contract with their custodian bank or a third party to lend their securities, so “the personnel in the institutional investor with responsibility for voting the shares may not even be aware that the shares are out ‘on loan’.”[54] Therefore, all kinds beneficial shareholders are not aware at any given time how much, if any, of their interest in a corporation has been temporarily transferred to a buyer.[55]

This lack of knowledge is problematic because the beneficial owner will be surprised that they cannot vote shares that they think they own. If shares are out on ‘loan’ on the ‘record’ date for the shareholder meeting,[56] then the shareholder whose shares have been lent out does not get to vote, even if title transfers back to them before the vote is held. The ‘record’ shareholder’s interests undoubtedly diverge from, and can even be antithetical to, the surprised lender’s interests. Even in the best-case scenario, since institutional investors are more likely to engage in share lending, and are also more likely to engage with corporate voting, than other shareholders, the net effect of share lending is to reduce informed engagement in the process.[57]

Share lending also leads to over-voting. Standard brokerage agreements allow brokers to lend out shares without notifying clients and, since shares are held in fungible bulk with pro rata book-entry interests,[58] brokers do not attempt to identify which customer’s shares they are lending. How this leads to over-voting is illustrated by the following example:

Suppose that Morgan Stanley has 1 million shares of Delaware, Inc. in its DTC account, while Smith Barney has 500,000 shares in its account. A hedge fund customer “borrows” 100,000 shares from Morgan Stanley and, to go short, sells them to a customer of Smith Barney. Once that sale is completed, the DTC records will show that Smith Barney has 600,000 shares, while Morgan Stanley now has 900,000 shares. … DTC’s omnibus proxy will transfer the right to vote 900,000 shares to Morgan Stanley, and will inform Broadridge of this. Morgan Stanley, however, will give Broadridge a list of all its customers’ holdings in Delaware, Inc. for a total of 1 million shares. Broadridge will then send out proxy materials according to the brokers’ customer lists, with the result that it will solicit voting instructions for more shares than are in fact entitled to vote.[59]

To help mitigate this issue, Broadridge provides an “Over Reporting Prevention Service” that compares “a participant’s reported position to its DTC position, flags any differences, and enables the participant to make appropriate adjustments.”[60] Still, it occurs with some frequency. In uncontested votes, Broadridge resolves over-votes through an opaque internal reconciliation.[61] There are no standard practices for dealing with over-votes, so Broadridge can reconcile a vote however they think best.[62] If too many votes are submitted by a custodian in a contested election, the inspector may contact the custodian and ask them to reconcile the difference between its submitted and entitled votes.[63] Some brokers refuse to do so, such as Deutsche Bank from 1998 to 2003 despite (or maybe because of) the fact that Deutsche Bank had a habit of submitting far too many votes.[64]

Reconciliation is important. Although the question of how a custodian should reconcile an over-vote remains unanswered,[65] failure to do so may lead to invalidation of the custodian’s whole submission, or uncertainty about which votes were actually counted by the inspector. Since there are no standard tabulator practices for dealing with over-votes, tabulators “may respond … with a variety of vote-counting procedures, including counting votes on a first in-first voted or last in-first voted basis ….”[66] Beneficial shareholders rarely receive notice of when, or even if, the tabulator received their votes.[67] Inspectors can also invalidate all votes from a party that submits too many votes.[68] No result is ideal for shareholders, who cannot be sure their votes were ever counted by their custodian, Broadridge, or the tabulator (if different from Broadridge).

Economic Interest Problems – Incidental Discrepancies and Empty Voting

Separate and apart from the issues created by intermediation, problems can arise from the divergence between voting rights and economic interest because (1) shares are bought or sold after the record date and before the vote, such that a person gets to vote shares at a meeting that he no longer owns (or cannot vote shares at the meeting despite owning shares), and (2) the beneficial shareholder is hedged against company-specific risk.[69]

Sometimes the divergence between voting rights and economic interest occurs “as an unintended consequence of a transaction undertaken for other reasons.”[70] Those with voting rights and no economic interest may fail to vote, cast a less-informed vote, or look to the investor with the economic interest for instructions on how to vote.[71] Those with an economic interest and no vote lose voice, and their omission from the voting process adds uncertainty to the validity of, especially, close shareholder votes.

Divergence between voting rights and economic interest also occurs intentionally, leading to ‘empty voting.’[72] Although the practical significance of empty voting is contested at a systemic level, it can be important in individual transactions.[73] By way of example, in late 2004 Mylan Labs agreed to

buy King [Pharmaceuticals] in a stock-for-stock merger …. To help Mylan obtain shareholder approval for the merger, Perry[, a large King shareholder,] bought 9.9% of Mylan – becoming Mylan’s largest shareholder – but fully hedged the market risk associated with its Mylan shares. Perry thus had 9.9% voting ownership of Mylan but zero economic ownership. Including its position in King, Perry’s overall economic interest in Mylan was negative. The more Mylan (over)paid for King, the more Perry stood to profit.[74]

Clearly, empty voting can “result in systematically inferior voting outcomes.”[75]


Comparative Proxy Voting[76]

The previous section reviewed how and why the U.S. model of proxy voting is complex and untrustworthy. Such shortcomings are also unnecessary. Many other jurisdictions have structured intermediated shareholding and corporate voting in ways that avoid many of the issues discussed in U.S. voting.

There are three major points of distinction between the U.S. and other national systems. First, legal structures in other countries provide beneficial investors with more, or even direct, rights in shares, as opposed to our system of securities entitlements. Second, other countries provide issuers greater transparency about the identity of beneficial investors. Third, voting materials in other countries are distributed more directly from issuers to beneficial investors, and back, than in the U.S.

The following subsections are categorized by the legal structure of intermediated shareholding, starting with full individual ownership of shares, and then moving to other structures. The issues of transparency and voting mechanics, which can diverge between countries with the same legal entitlements, are addressed within each subsection.

Spain & France – Dematerialization, Direct Registration, and Individual Ownership

Spain and France share a model of direct share registration that is the most practical and comprehensive way to deal with many of the problems that plague U.S. corporate voting.

The first structural difference between the Spanish/French and American models is that Spain and France have “dematerialized” corporate shares. Whereas the U.S. immobilized share certificates to alleviate the paper crunch in the 1970s, Spain and France have done away with share certificates altogether, making pure book-entry mandatory for public companies.[77] The same can be done in the U.S. “U.C.C. Article 8 already permits uncertificated securities and provides a legal structure for transfer. Under states’ corporate laws, corporations may issue uncertificated equity securities. Uncertificated bonds are already very common.”[78]

The second, crucial, structural difference is that Spain’s (and France’s) version of DTCC, IBERCLEAR, maintains a transparent book-entry registry for corporate shares in the names of beneficial owners.[79] Thus, Spanish issuers benefit from IBERCLEAR’s up-to-date list of all their beneficial owners. DTCC has a similar, optional Direct Registration System (“DRS”), which has been in operation since 1996; so the infrastructure to adopt the Spanish/French model already exists.[80] The creation and use of DRS are discussed in the next section.

The legal difference between Spain and France, and America is also stark. Beneficial investors in Spanish or French listed firms enjoy “full, individual” share ownership, because their shares “are deemed to be located directly in the investor’s securities account.”[81] Intermediaries like IBERCLEAR and custodians have no ownership interest in the stock,[82] in contrast to Cede and American custodians, which pass legal rights down the chain of intermediaries. The individual ownership model is represented below:[83]


The individual ownership model also simplifies the voting process. In France, registered shareholders receive material directly from, and vote directly with, the issuer, whether or not the shares are held through an intermediary. In Spain, in contrast to many other countries, the primary mode of disseminating meeting notice and proxy information is through websites, in order to comply with Spanish law requiring “quick and non-discriminatory access” to meeting information for all investors.[84] Beneficial investors then vote directly with the issuer or pass voting instructions up their chain of intermediaries through IBERCLEAR’s participants. The voting processes for both countries are depicted below:[85]



Spain and France’s individual ownership model solve a host of problems. IBERCLEAR’s real-time registry of beneficial shareholders simplifies the creation of the record-holder list. The lag between the record date and vote date in Spain is only five days,[86] compared to between 10 and 60 days for Delaware companies.[87] Shorter intervals between the record voting dates reduce the possibility of lending surprise and incidental empty voting.[88] Even with a shorter turn-around, materials are more likely to arrive because intermediaries are eliminated from many steps.[89] Verification of votes and voting instructions is much simpler, since materials are sent directly from the issuer to beneficial shareholders. Finally, since the record-holder list continually updates, there is little risk of over-voting.[90]

Germany – Co-ownership

Germany has a model that combines elements of the individual ownership and the American models. Like America, shares are certificated, immobilized at a central securities depositary (“Clearstream Frankfurt”), and held in fungible bulk. Like Spain and France, Germany recognizes beneficial shareholders’ rights as direct shareholders in the fungible bulk held at the central securities depositary. Therefore, although it is not possible to identify a particular investor’s specific holdings, that investor is still entitled to exercise and “enforce the rights attached to the securities.”[91] The co-ownership model is represented below:[92]


The German system is also more transparent for issuers than America’s system. For years, German corporations could request and obtain a complete list of beneficial shareholders and the number of shares they owned from intermediaries.[93] The right of German issuers to compel disclosure only augmented an already transparent system. Clearstream Frankfurt’s direct registration system accounted for 50% of all shares issued by DAX 30 companies in 2015, far higher than the participation rate in DTCC’s DRS.[94] Updates to Clearstream’s DRS are reported to issuers daily.[95] Recently, in mid-2018, Germany implemented an even more transparent shareholder registry, requiring that companies maintain a complete registry of beneficial shareholders who own at least one share.[96]

Although the shareholder records of German companies are transparent, the dissemination of vote information remains intermediated and even incomplete, sometimes not reaching beneficial shareholders. Issuers are required to send vote communications to all registered shareholders, but neither the issuer nor intermediaries have any obligation to pass communications or voting rights to beneficial shareholders.[97] If voting information is disseminated to beneficial shareholders, the shareholders can be authorized by intermediaries either to return VIFs to the custodian, who then votes, or to vote directly.[98] Germany’s voting process is depicted below:[99]


England & Australia – Trusts

The intermediated shareholding model in England and Australia looks more like America’s model, but legal rights enter and pass down the intermediary chain through the legal concept of trusts, rather than contract. Issuers deposit securities with England’s version of DTCC, Euroclear (or “CREST”), or Australia’s version, CHESS.[100] However, unlike DTCC, which technically enjoys initial ownership via Cede, Euroclear and CHESS simply hold the securities in trust for their participants, who are the first level of legal shareholders.[101] Each intermediary then holds the securities in trust for its accountholders, on down to beneficial shareholders.[102] Accountholders below Euroclear or CHESS’s participants have equitable interests in the trust property of their custodian,[103] rather than property interests in the shares like in France or Germany, or interests in securities entitlements like in the U.S. The trust model is represented below:[104]


Holdings through the trust structure are afforded roughly equivalent transparency in both countries, which are similar to Germany’s rules before mid-2018. Australia’s Corporations Act, section 672A lets issuers request that nominees disclose for whom they hold shares.[105]  Nominees must comply or they may be liable for damages.[106] Similarly, beneficial investors in England are not immediately visible to issuers, but “public companies are entitled to obtain details of all persons who are interested in their shares, including beneficial owners.”[107] However, unlike Euroclear, CHESS offers a DRS option, allowing beneficial shareholders to register with it directly and providing greater transparency for issuers.[108]

Australia’s voting rules are very similar to those in the U.S.[109] Voting rights vest with the registered shareholders, and intermediaries and beneficial shareholders only receive rights granted in their trust agreement. Therefore, proxy materials must be sent only to registered shareholders, who are mostly custodian intermediaries. Materials sometimes must be passed down through multiple tiers of intermediaries. When beneficial shareholders do vote, they either send VIFs to their custodian or send their vote to the issuer, depending on the terms of the beneficial shareholder’s trust agreement.

England’s voting process is largely the same, even though English law provides the option for more direct voting communication between issuers and beneficial shareholders, because the option to enable direct beneficial shareholder communications is not used[110] in practice.[111]  Despite the familiar presence of intermediary chains passing along voting materials, both England and Australia require that the record and meeting dates be no more than 48 hours apart.[112] The voting processes for both countries are depicted below:[113]




Technological Solutions

In addition to potentially borrowing processes from other jurisdictions, there are also practical technological solutions that can help alleviate some or most of the problems with corporate proxy voting.

Direct Registration

Reliable infrastructure, proven to simplify proxy voting by disintermediating securities holding, already exists. DTCC has a Direct Registration System (“DRS”) that “enables investors to elect to hold their assets in book entry form directly with the issuer,” which “provides investors with an alternative to holding their securities in certificate or ‘street’ form.”[114] There are no legal impediments to using the DRS. All states’ laws allow corporations to issue shares without paper certificates.[115] There are no issuer capability impediments to using the DRS. All U.S. stock exchanges require that issuers be capable of participating in the DRS.[116] And DRS is not new and novel. Industry participants discussed direct registration as a component of reducing settlement times to T+3 in the 1980s and early 1990s.[117] Although the “elimination of certificates was not necessary … to achieve a shorter settlement cycle,” an operational DRS was eventually approved by the SEC in 1996,[118] and came online in November of that year.[119]

However, DRS “is little used.”[120] One reason is because brokers’ internal systems are often better suited for the needs of investors who trade frequently or who require prompt execution of trades, even though DRS “[s]upported the industry move to T+2”, which is current standard practice, “and will support the move to T+1.”[121] Trading directly registered shares requires that the shares first be transferred and re-registered with a broker before getting traded.[122] Therefore, investors cannot “buy or sell at a specific market price or at a specific time. Instead, the company will purchase or sell shares … on a daily, weekly, or monthly basis – and at an average market price.”[123] The time for this extra step might have a material financial impact. Another reason for the lack of direct registration is that each transfer from the issuer’s books, through the DRS, to the broker, “will generate a fee for DTCC and the broker,” incentivizing rational shareholders seeking liquidity to “avoid direct holding.”[124] Finally, shareholders who wish to remain anonymous vis-à-vis the issuer cannot participate in direct registration, unless they designate a nominee to hold their shares for them.[125]

Opposition to a wholesale change to a direct registration system comes from entrenched interests. Broadridge has a monopoly over information processing in the current system, which it loses with universal direct registration.[126] Brokers also oppose change. They will oppose any DRS that eliminates their client relationships, and they may even oppose a multi-tier system because it will make the lucrative securities-lending business more costly, since customers’ specific securities would become identifiable.[127]

Direct Online Proxy Delivery

The internet provides another potential solution, but its efficient use requires legal reform. The Business Roundtable provided a framework for such reform in a letter to the SEC in 2004.[128]

First, the Business Roundtable recommended that the SEC require that agents “pass voting rights directly to beneficial owners by executing omnibus proxies in their favor.”[129] DTCC already sends omnibus proxies to its participants, and they in turn “are already required to execute omnibus proxies to pass voting rights to respondent banks.”[130] Completing the chain of voting rights directly to beneficial owners, instead of sending out voting instruction forms, “would simplify the voting and tabulation process” by letting shareholders vote directly, rather than sending their votes back through intermediaries. Issuers could then expand the use of their internet voting systems from record holders to all beneficial owners.[131]

Full implementation of this revised voting structure requires implementation of the Business Roundtable’s second recommendation: that the SEC eliminate the distinction between NOBOs and OBOs. Eliminating the distinction would allow issuers to communicate directly with all their beneficial shareholders, except those who take other steps, such as creating a nominee account, to retain anonymity.[132] The Business Roundtable contends that this will place more of the costs of anonymity on those who wish to remain anonymous, rather than imposing severe systemic costs on issuers and other shareholders. Even still, under SEC rules, companies may only send certain communications directly to NOBOs. Proxies must still be distributed by intermediaries.[133]

Therefore, the Business Roundtable also recommended that the SEC allow issuers to deliver proxy materials directly to shareholders.[134] This would replace the current “notice and access” model,[135] where notice must travel from the issuer through intermediaries to the beneficial owner, with one where the issuer would send proxy material directly to beneficial owners via email or mail. Direct proxy delivery was considered by the SEC in 1982, and rejected because technical and cost barriers were too high.[136] Clearly, the capabilities and costs of information technology have transformed since 1982. However, state corporation law remains an impediment to this third recommendation. It recognizes the registered shareholder as legal owner, and shares are registered with Cede & Co., which transfers rights to its participants. Until the law changes “communication will remain disrupted and at best indirect,” because every intermediary in the chain must affirmatively delegate voting rights through to beneficial shareholders.[137]

Distributed Ledgers

The most promising technology of all is distributed ledgers (“DLT”), the most famous type of which is blockchain.

Distributed ledgers are “nothing but a registration of a chain of ownership.”[138] DLT relies on networked computers to verify transactions, thereby maintaining a trustworthy ledger that does not require trust between trade counterparties nor reliance on a central clearing party. The ledger itself is “stored across many servers, which communicate to ensure the most accurate and up to date record of transactions ….”[139] This distributed ledger is a major change from current shareholding infrastructure. Today, every intermediary maintains their own ledger, reflecting the holdings of their accountholders. In a DLT network, every participating institution has access to the same ledger, reflecting the holdings of all accountholders at all institutions.[140] The following two illustrations show the difference between today’s ledgers and a DLT ledger. The first shows the steps required for a street name investor to trade with another street name investor through their custodians (“Account management institutions” in the illustration) and DTCC (“Book-entry transfer institution” in the illustration):[141]


The second illustration shows how that same trade is booked through a DLT network:[142]


DLT can be implemented by either a single party, who dictates the network’s structure, purpose, and function, or the administration of a DLT network can itself be decentralized, allowing “the public and users to have a say in how it’s structured and run.”[143]

Blockchain is a specific form of DLT. Computers in a blockchain network solve algorithms to verify transactions, and the transactions are then added to the ledger. A sufficiently large sequence of transactions, a “block,” is then cryptographically added onto the “chain” of transactions existing in the ledger. Therefore, blockchain ledgers cannot be changed once they are encrypted.[144]

Securities can be legally issued on DLT. Overstock conducted the first securities offering using blockchain in 2016.[145] Securities issued on a DLT can fall within UCC Article 8’s definition of uncertificated securities.[146] And the SEC recently published a Framework for “Investment Contract” Analysis of Digital Assets, providing guidance on uncertificated DLT securities offerings.[147]

DLT is already in early-stage testing and implementation in markets around the world. NASDAQ and Deutsche Borse began investigating blockchain in 2015.[148] That same year, more than 50 financial institutions, including Goldman Sachs, J.P. Morgan Chase, and Bank of America, created a consortium called R3, which “is an enterprise blockchain software firm” that now has offices and operations around the world.[149] DTCC contracted with IBM and DLT startup Axoni[150] in early 2017 to transform its Trade Information Warehouse, the basis for DTCC’s derivatives market, into a DLT network.[151] DTCC’s network entered its first public test phase in late 2018.[152]

DLT could “make intermediaries obsolete or pave the way for new, more efficient … securities settlement.”[153] For example, on April 5, 2019, R3, Barclays, and Royal Bank of Scotland completed a test trial demonstrating that real estate settlement can be reduced from three months to less than three weeks using DLT.[154] Settlement of securities transactions might become faster because distributed networks allow “[d]irect reconciliation” between computers, as opposed to the current model which requires “a great deal of reconciliation” by custodians.[155] Therefore, “DLT could [also] do away with the need for dedicated systems run by intermediaries.”[156] Theoretically, “if two [computers] make a matching declaration in the distributed ledger, the entry in the distributed ledger could be simultaneously interpreted as the trade, clearing, settlement and accounting.”[157]

Most optimistically, DLT can be used to collect votes, in addition to simplifying the voting process by reducing settlement lag and the number of intermediaries. Securities owners registered on the ledger would receive tokens in advance of a vote, which “they could transmit to addresses on the blockchain to register their preferences.”[158] In fact, NASDAQ Talinn (Estonia) “announced a pilot program for blockchain voting,” in February 2016.[159]

Regulatory Reforms

In such a complex system there are ample opportunities for reform.

Some reforms are relatively simple and will not fundamentally change the system, even though they increase beneficial shareholder awareness and participation. The SEC could eliminate the NOBO/OBO distinction, in line with the Business Roundtable’s suggested reforms, thereby increasing transparency for issuers. States or the SEC could require that meeting notices and vote information be posted on issuers’ websites or other online bulletins, as in Spain. States might standardize the reconciliation procedures at Broadridge and other tabulators, and either the states or the SEC can require that reconciliation procedures be published to improve transparency.

Other potential reforms change the fundamental nature of intermediated shareholding in the U.S. For example, beneficial shareholders could enjoy proprietary rights in shares, as in Spain, France, and Germany, as opposed to rights in securities entitlements. Or regulators might give issuers coercive capacity to demand lists of beneficial owners from intermediaries, subject to non-compliance penalties, a power enjoyed by issuers in many foreign jurisdictions. Perhaps the most promising and comprehensive reform would be to move from certificated immobilized shares to dematerialized shares, owned individually, as reflected in customers’ bank or broker accounts. Beneficial shareholders or their nominees would also be the registered shareholders, and “intermediaries would process and communicate trading information, not own securities and information about ‘beneficial’ owners.”[160] The legal change can be accomplished without “a radical redesign of settlement infrastructure,”[161] especially since DRS already exists in the U.S. and similar versions are in operation around the world. Additionally, after DLT is implemented, it can provide near instantaneous settlement and recognition of beneficial shareholder’s interests if both issuers and intermediaries participate in the same DLT networks.

A third type of reform – some form of audit requirement – is not necessarily simple nor fundamental with respect to its impact on intermediated proxy voting. There are at least three versions of audit requirements that could be put in place. First, regulators could require that intermediaries or tabulators inform beneficial shareholders when their voting instructions arrive and/or when their proxies are counted. Second, regulators could simply require that tabulators be able to ascertain the origin of votes. Third, Delaware or other state judges could place the burden of persuasion, when attempting to prove that a proposition passed, on the proponent, thereby encouraging parties to enhance their vote auditing capabilities.[162] Under the first two versions of an audit requirement, issuers, DTCC, and custodians are incentivized to develop the mechanisms for providing the required transparency. Under the third version, activist shareholders also have incentives to improve audit trails.

Despite the complexity and opacity of U.S. corporate voting, audits are possible. The Securities Industry End to End Vote Confirmation Steering Committee concluded in 2016, after four years of testing, that end-to-end vote confirmation is viable.[163] Broadridge now offers a vote confirmation service, called ProxyEdge.[164] Advances in audit validity could come through any number of channels. It might be facilitated by technological change, such as DLT; legal arrangements, like authorizing beneficial shareholders to both receive information directly from issuers and vote online; and industry standards, like custodian and tabulator vote reconciliation practices. Moreover, if the SEC promulgated the audit requirement, that might spur states, like Delaware or others looking to attract corporations, to reform their corporate codes to facilitate vote transparency. With the right incentives, transparency and accuracy can quickly become hallmarks of U.S. corporate voting.



[1] Marcel Kahan and Edward Rock, The Hanging Chads of Corporate Voting, 96 The Georgetown L.J. 1227, 1279 (2008).
[2] There are several in-depth, publicly available articles describing intermediated shareholding and the proxy voting process from which this memo draws, including: Kahan and Rock, supra note 1; Concept Release on the U.S. Proxy System, Exchange Act Release No. 62495, 2010 WL 2779423 (July 14, 2010) [hereinafter Proxy Plumbing Release], available at http://www.sec.gov/rules/concept/2010/34-62495.pdf; David C. Donald, Heart of Darkness: The Problem at the Core of the US Proxy System and Its Solution, Centre for Fin. Reg. and Econ. Dev. Working paper No. 1 (Oct. 20, 2010); Richard W. Barrett, Elephant in the Boardroom?: Counting the Vote in Corporate Elections, 44 Valparaiso Uni. L. Rev. 125 (2009); George S. Geis, Traceable Shares and Corporate Law, Uni. of Virginia School of Law Public Law and Legal Theory Research Paper Series 2018-13 (Feb. 23, 2018). Reference these sources for greater depth and nuance.
[3] Respondent banks are banks that have client accounts at DTCC-member, or other, banks.
[4] Donald, supra note 2, at 15 (listing DTCC’s holdings in 2009 at $33.9 trillion); Depository Trust & Clearing Corporation, Annual Report 2017 at 69 (2017).
[5] Market capitalization of listed domestic companies (current US$), World Bank Group, https://datacatalog.worldbank.org/public-licenses#cc-by (last visited Apr. 10, 2019).
[6] All corporations keep a list or record of their “registered” shareholders.
[7] Geis, supra note 2, at 6.
[8] Geis, supra note 2, at 9.
[9] Kahan and Rock, supra note 1, at 1239.
[10] After netting.
[11] Kahan and Rock, supra note 1, at 1241.
[12] Securities entitlements are “the rights and property interest of an entitlement holder with respect to a financial asset ….” U.C.C. § 8-102(a)(17).
[13] Kahan and Rock, supra note 1, at 1242. A financial asset is “(i) a security; (ii) an obligation of a person or a share, participation or other interest in a person or in property or an enterprise of a person, which is, or is of a type, dealt in or traded on financial markets, or which is recognized in any area in which it is issued or dealt in as a medium for investment; or (iii) any property that is held by a securities intermediary for another person in a securities account if the securities intermediary has expressly agreed with the other person that the property is to be treated as a financial asset under this Article.” U.C.C. § 8-102(a)(9).
[14] Id.
[15] Id.
[16] Id. at 1243.
[17] Id. at 1236.
[18] Barrett, supra note 2, at 152.
[19] “The corporation ought not to be involved in possible misunderstandings or clashes of opinion between the non-registered and registered holder of shares. It may rightfully look to the corporate books as the sole evidence of membership.” Salt Dome Oil Corp. v. Schenck, 41 A.2d 583, 589 (Del. 1945).
[20] FAQs Regarding the SEC’s NOBO-OBO Rules and Companies’ Ability to Communicate with Retail Shareholders, KattenMuchinRosenman llp, https://www.kattenlaw.com/nobo (Jan. 4, 2010).
[21] Id.
[22] Bus. Roundtable, Request for Rulemaking Concerning Shareholder Communications, Letter to SEC dated April 12, 2004, http://www.sec.gov/rules/petitions/petn4-493.htm#P45_11983.
[23] Kahan and Rock, supra note 1, at 1279.
[24] Donald, supra note 2, at 20. See any of the papers in note 2 for more detail about the mechanics of corporations setting up shareholder votes.
[25] Proxy Plumbing Report, supra note 2, at 23.
[26] Kahan and Rock, supra note 1, at 1236.
[27] Barrett, supra note 2, at 153.
[28] Kahan and Rock, supra note 1, at 1246.
[29] Barrett, supra note 2, at 153–58 (some footnotes omitted).
[30] 17 C.F.R. §§ 240.14a-13(a)–(a)(1)(i)(A); 240.14a-13(a)(4)–(5); 240.14a-13, Note 1.
[31] 17 C.F.R. § 240.14b-1(c)(2)(i); 240.14b-2(a)(5)(c)(2)(i).
[32] John C. Wilcox, John J. Purcell III, & Hye-Won Choi, “Street Name” Registration & The Proxy Solicitation Process, in A Practical Guide to SEC Proxy and Compensation Rules 12-10 (Amy L. Goodman & John F. Olson eds., 3rd ed. Supp. 2007).
[33] Broadridge serves as official tabulator for about 1,800 public companies. Recommendations, Impartiality in the Disclosure of Preliminary Voting Results, Investor Advisory Committee 7 (Oct. 9, 2014), https://www.sec.gov/spotlight/investor-advisory-committee-2012/impartiality-disclosure-prelim-voting-results.pdf. 
[34] Official tabulators are often issuers’ transfer agents “because most major transfer agents have the infrastructure to communicate with registered holders, proxy service providers, and securities intermediaries, while also being able to reconcile the identity of voters that are registered owners and the number of votes to the issuer’s records.” Proxy Plumbing Release, supra note 2, at 24.
[35] For example, Delaware corporations that list shares on a national exchange or have more than 2,000 record shareholders must appoint inspectors of election for any shareholder meeting. Del. Code tit. 8 § 231(a) (2009). There are no statutory requirements for inspectors’ qualifications or independence.
[36] Kahan and Rock, supra note 1, at 1249.
[37] Id.
[38] Id. at 1251.
[39] Steven Brull, The Best-Laid Plans …, Institutional Investor Americas, Feb. 2004, at 38.
[40] Dale A. Oesterle & Alan R. Palmiter, Judicial Schizophrenia in Shareholder Voting Cases, 79 Iowa L. Rev. 485, 510–11 (1994).
[41] See Kahan and Rock, supra note 1, at 1250–51.
[42] John C. Wilcox, Shareholder Nominations of Corporate Directors: Unintended Consequences and the Case for Reform of the U.S. Proxy System, in Shareholder Access to the Corporate Ballot 6 (Lucian A. Bebchuk ed., 2004).
[43] Id.
[44] Kahan and Rock, supra note 1, at 1254.
[45] Id.
[46] Id. at 1253.
[47] Id.
[48] Id.
[49] Id. The consequences of over-voting are treated in the following section.
[50] Id. at 1254.
[51] Id.
[52] Fully Paid Securities Lending, BNY Mellon, https://www.pershing.com/what-we-provide/investment-solutions/topics/fully-paid-securities-lending (last visited Apr. 10, 2019) (advertising the benefits of share lending for brokerage account holders as participation in the loan fee and interest earned on the cash collateral).
[53] Press Release, Cal. Office of Pub. Affairs, CalPERS Approves Investment Contracts – Asset Allocation, Supplemental Savings, Securities Lending (June 19, 2006), available at http://www.calpers.
ca.gov/index.jsp?bc_/about/press/pr-2006/june/approves-investment-contracts.xml.
[54] Kahan and Rock, supra note 1, at 1256.
[55] Id.
[56] The record date is the day on which the official shareholder list is frozen to decide who gets to vote in the upcoming election.
[57] Kahan and Rock, supra note 1, at 1256–57.
[58] UCC Article 8, discussed supra page 2.
[59] Kahan and Rock, supra note 1, at 1259.
[60] Letter from Donald Kittel, Executive Vice President, Sec. Indus. Assoc., to Anand Ramtahal, Vice President of Member Firm Regulation, NYSE 2 (Apr. 26, 2005), available at http://www.sifma.org/regulatory/comment_letters/comment_letter_archives/6136.pdf [hereinafter SIA Letter] (as of 2004, 100 brokers representing more than 90% of street positions used the service).
[61] Kahan and Rock, supra note 1, at 1260 fn. 132.
[62] Id. at 1262.
[63] Id. at 1260.
[64] Id. at 1260–61 (recounting that Deutsche once submitted over 8.5 million votes when it was only entitled to cast 4.3 million; and in another instance cast almost 11.2 million votes when it was only eligible to cast about 6.7 million. Over-voting occurred in 12 of 15 and 11 of 12 instances tested over two time periods).
[65] Kahan and Rock, supra note 1, at 1262.
[66] In re Deutsche Bank Securities Inc., NYSE Decision 05-45, para. 11 (Feb. 2, 2006).
[67] Supra page 7, list point 5.
[68] E.g., Id.; Seidman & Assocs., L.L.C. v. G.A. Fin., Inc., 837 A.2d 21, 24–25 (Del. Ch. 2003) (invalidating proxies for 233,376 shares when unable to resolve an 824-share overvote).
[69] Kahan and Rock, supra note 1, at 1263.
[70] Id. at 1264.
[71] Id. at 1264–65.
[72] Henry T.C. Hu & Bernard Black, Empty Voting and Hidden (Morphable) Ownership: Taxonomy, Implications, and Reforms, 61 Bus. Law. 1011 (2006).
[73] Kahan and Rock, supra note 1, at 1265.
[74] Hu and Black, supra note 55, at 1015.
[75] Kahan and Rock, supra note 1, at 1267; but see Onnig H. Dombalagian, Can Borrowing Shares Vindicate Shareholder Primacy?, 42 Uni. of Cal. Davis L. Rev. 1231 (2009).
[76] This section covers Spain, France, Germany, the UK, and Australia. For more countries, including China and Japan, see Transparency of Share Ownership, Shareholder Communications and Voting in Global Capital Markets, Computershare/Georgeson (Mar. 2015).
[77] E.g., Kahan and Rock, supra note 1, at 1274; Securities Registration System, iberclear, http://www.iberclear.es/ing/Services/Securities-Registration-System (last visited Apr. 11, 2019).
[78] Kahan and Rock, supra note 1, at 1278.
[79] Id. China and Brazil also have so-called “transparent” shareholder registries. Luc Thevenoz, Who Holds (Intermediates) Securities? Shareholders, Account Holders, and Nominees, XV Uniform Law Review 845, 846 (2010).
[80] Infra, page 9.
[81] Legislative Guide on Intermediated Securities, Unidroit 17 (2019), available at https://unidroit.org/instruments/capital-markets/legislative-guide.
[82] Id.
[83] Id.
[84] Transparency of Share Ownership, Shareholder Communications and Voting in Global Capital Markets, Computershare/Georgeson 23 (Mar. 2015).
[85] Id. at 15, 23.
[86] Art. CIV of the Public Companies Act.
[87] Del. Code Ann. tit. 8, § 213 (2001).
[88] Kahan and Rock, supra note 1, at 1268.
[89] Id.
[90] Id. at 1277. Some risk still exists if intermediaries enter trades incorrectly or slowly. Iberclear demands that intermediaries “keep the detailed register up to date at all times, by entering every single trade performed by the entities with third parties, or on the orders of the latter, that impacts the ownership or availability of the securities ….” Securities Registration System, iberclear, http://www.iberclear.es/ing/Services/Securities-Registration-System (last visited Apr. 11, 2019).
[91] Unidroit, supra note 81, at 18.
[92] Unidroit, supra note 81, at 19.
[93] Dirk Zetzsche, Shareholder Passivity, Cross-Border Voting and the Shareholder Rights Directive 38 (July, 2008).
[94] Transparency of Share Ownership, Shareholder Communications and Voting in Global Capital Markets, Computershare/Georgeson 16 (Mar. 2015).
[95] Id.
[96] Andreas Jurgens, News Update on GmbH Shareholders’ List, ReedSmith (Sept. 10, 2018), https://www.reedsmith.com/en/perspectives/2018/09/news-update-on-gmbh-shareholders-list; Andreas Jurgens, New Legal Requirements For GmbH-Shareholders’ List, ReedSmith (July 10, 2017), https://www.reedsmith.com/en/perspectives/2017/07/new-legal-requirements-for-gmbh-shareholders-list.
[97] Computershare/Georgeson, supra note 94, at 16.
[98] Id.
[99] Id.
[100] Central securities depositories, Fin. Conduct Auth., https://www.fca.org.uk/markets/central-securities-depositories (last updated Nov. 22, 2018); Computershare/Georgeson, supra note 94, at 4.
[101] Unidroit, supra note 81, at 19.
[102] Id.
[103] Id.
[104] Id. at 20.
[105] Computershare/Georgeson, supra note 94, at 4.
[106] Id.
[107] Bus. Roundtable, supra note 22.
[108] Computershare/Georgeson, supra note 94, at 4.
[109] Id. at 5.
[110] As of 2015.
[111] Computershare/Georgeson, supra note 94, at 20.
[112] Paul Myners, Report to the Shareholder Voting Working Group (Jan. 2004), available at http://www.shareholdercoalition.com/sites/default/files/Myners%20Report%201-04_0.pdf; Computershare/Georgeson, supra note 94, at 5.
[113] Id. at 5, 20.
[114] Direct Registration System, The Depository Trust & Clearing Corporation, http://www.dtcc.com/settlement-and-asset-services/securities-processing/direct-registration-system (last visited Apr. 4, 2019).
[115] Barrett, supra note 2, at 165.
[116] SEC Release No. 34-54289, Order Granting Approval to Mandate Listed Companies Become Eligible to Participate in DRS (Aug. 8, 2006), 71 Fed. Reg. 47278 (Aug. 16, 2008) [File No. SR-NYSE-2006-29] (setting a DRS implementation deadlines for issuers and exchanges, including a final deadline for all listed stocks to achieve DRS compatibility by Jan. 2008, later extended to Mar. 2008); e.g., NYSE Listed Company Manual, § 501.00(B).
[117] Concept Release, Transfer Agents Operating Direct Registration System, Exchange Act Release No. 34-35038, 59 Fed. Reg. 63652, 63653 (Dec. 8, 1994). T+[x] refers to the number of days after a trade is placed that it settles. T+3 means that a stock trade settles three days after it is placed.
[118] SEC Release No. 37391, Order Granting Approval to Establish DRS (Nov. 7, 1996), [File No. SR-DTC-96-15] (approving establishment of DRS to provide cost-efficient transfers, prompt settlement of trades, and reduction in problems related to lost or stolen certificates).
[119] Donald, supra note 2, at 37; Concept Release, Transfer Agents Operating Direct Registration System, Exchange Act Release No. 34-35038, 59 Fed. Reg. 63652, 63653 (Dec. 8, 1994).
[120] Barrett, supra note 2, at 165.
[121] Direct Registration System, supra note 4.
[122] SEC, Holding Your Securities – Get the Facts, http://www.sec.gov/investor/pubs/holdsec.htm.
[123] Id.
[124] Donald, supra note 2, at 37.
[125] Kahan and Rock, supra note 1, at 1278–79.
[126] Id.
[127] Id. at 1279; Donald, supra note 2, at 38–9.
[128] Bus. Roundtable, supra note 22.
[129] Id.
[130] Id.
[131] Id.
[132] Id.
[133] Donald, supra note 2, at 18.
[134] Bus. Roundtable, supra note 22.
[135] Under SEC rules issuers are allowed to post proxies online. Issuers send a Notice of Internet Availability of Proxy Materials to beneficial shareholders through intermediaries. This process is called “notice and access.”
[136] Advisory Committee on Shareholder Communications, SEC, Improving Communications between Issuers and Beneficial Owners of Nominee Held Securities 69 (1982).
[137] Donald, supra note 2, at 18.
[138] Jeanne L. Schroeder, Bitcoin and the Uniform Commercial Code, 24 U. Miami Bus. L. Rev. 1 (2016).
[139] Matthew Beedham, Here’s the difference between blockchain and distributed ledger technology, The Next Web B.V. (July 27, 2018), https://thenextweb.com/hardfork/2018/07/27/distributed-ledger-technology-blockchain/.
[140] Kenta Sekiguchi et al., The Securities Settlement System and Distributed Ledger Technology, Bank of Japan (June 5, 2018), http://www.boj.or.jp/en/research/wps_rev/lab/lab18e02.htm/.
[141] Id.
[142] Id.
[143] Matthew Beedham, supra note 139.
[144] Andrew Meola, How distributed ledger technology will change the way the world works, Business Insider (Oct. 5, 2017), https://www.businessinsider.com/blockchain-distributed-ledgers-2017-10.
[145] Michael del Castillo, Overstock Raises $10.9 Million in First Blockchain Stock Issuance, Coindesk (Dec. 15, 2016), https://www.coindesk.com/overstock-first-blockchain-stock-issuance.
[146] See e.g., Jeanne L. Schroeder, supra note 138.
[147] Framework for “Investment Contract” Analysis of Digital Assets, SEC.
[148] Bradley Hope and Michael J. Casey, A bitcoin technology gets Nasdaq test, The Wall St. J. (May 10, 2015); Anna Irrera, CME and Deustche Borse Join Blockchain Gang, Fin. News (July 20, 2015).
[150] In consultation with R3.
[151] Michael del Castillo, $11 Trillion Bet: DTCC to Process Derivatives With Blockchain Tech, Coindesk (Jan. 9, 2017), https://www.coindesk.com/11-trillion-bet-dtcc-clear-derivatives-blockchain-tech.
[152] Press Release, DTCC, DTCC Enters Test Phase on Distributed Ledger Project for Credit Derivatives with MarkitSERV & 15 Leading Global Banks (Nov. 6, 2018).
[154] Yogita Khatri, Barclays, RBS, R3 Cut Property Transaction Times in Blockchain, Coindesk (Apr. 5, 2019), https://www.coindesk.com/barclays-rbs-r3-cut-property-transaction-times-in-blockchain-trial.
[155] Deutsche Bundesbank, supra note 153, at 40 (the report also discusses DLT benefits, not discussed herein, like enhanced security, resilience, and identifiability, along with concerns).
[156] Id. at 41.
[157] Id. at 39.
[158] David Yermack, Corporate Governance and Blockchains, Rev. of Fin. 7, 23 (Jan. 10, 2017).
[159] Id. at 7, 23.
[160] Donald, supra note 2, at 43.
[161] Id.
[162] Kahan and Rock, supra note 1, at 1271.
[163] End-to-End Vote Confirmation Announcement, Securities Industry End to End Confirmation Steering Committee (May 2016).
[164] Presentation, End-to-End Vote Confirmation, Council of Institutional Investors 10 (Jan. 11, 2017), available at https://www.cii.org/files/events/2017/01_11_17_vote_confirmation.pdf.

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