Most CCOs have responsibility for developing a firm's supervisory systems, and thus, are subject to liability under the terms on the notice. As a result, while the FINRA guidance might have been intended to be comforting, it is doubtful that CCOs will find much relief in it. 

Tractor Supply Company asked to exclude a proposal related to "(1) whether the Company participates in compensation and workforce practices that prioritize Company financial performance over the economic and social costs and risks created by inequality and racial gender disparities and (2) the manner in which any such costs and risks threaten returns of diversified shareholders who rely on a stable and productive economy." 

Here is the website of . One can reasonably suppose that…

The firm's violation of Rule 2040 and broker-dealer registration requirements in this case was entirely straightforward and uncomplicated. There is simply no reason to throw in a "commercial honor" charge; Rule 2010 has been rendered absolutely meaningless by repetition. 

The facilitation of political and social arguments through corporate proxies is likely to produce some very uncomfortable and unforeseeable results. Might the SEC facilitate shareholder proxies that would prohibit doing business in countries that have disfavored or oppressive social, labor or political policies?