Final comment on DeutscheBörse/ISS merger: stock exchanges are to corporates what proxy advisors are to investors: data aggregators and coordinating agents that help overcome collective action problems. They represent two different sides of the #corpgov discourse. 1/5

A stock exchange taking over the largest p/a therefore cannot be neutral, in the same way that indices & ratings aren’t neutral but always involve a degree of judgement. Each exchange is different & DBörse hasn’t been as anti-investor as Nasdaq but caution is still warranted 2/5

What the industry needs is more & not fewer advisors. An oligopolistic industry structure is LT negative for quality of service asset managers receive as well as their margins. Looking at credit ratings agencies we’ve been waiting for years for a competitor to Moddy‘s and S&P 3/5

It’s a chicken and egg thing. Asset managers want more advisors each with a large coverage universe but aren’t prepared to fund these as they (until they) grow to sufficient scale to sit alongside ISS. 4/5 h/t @minerva_ESG

Here are some example of the sort of coordinating #corpgov activities stock exchanges get up to:

Nasdaq Letter to SEC:
https://www.nasdaq.com/articles/more-300-companies-join-nasdaq-sec-letter-2019-02-05

Nasdaq Opinion Piece:
https://www.nasdaq.com/articles/its-time-fix-proxy-process-2019-03-13

NYSE Letter to SEC:
https://www.sec.gov/comments/s7-22-19/s72219-7024782-215050.pdf

5/5