Should proxy advisory firms should be subject to greater Commission oversight and if so, what should that look like? Should there be checks on the accuracy of the information provided by proxy advisers? Are advisers who provide services to both corporations and investors managing and disclosing the resulting conflicts of interest appropriately? Are self-regulatory organizations appropriately overseeing proxy distribution fees?

Those are some of the questions the staff of Securities and Exchange Commission will ask when the agency publishes its "proxy plumbing" concept release soliciting input on how to modernize the voting infrastructure, SEC chairman Mary Schapiro told a group of directors.

In June 20 remarksat the Stanford University Law School Directors College, Schapiro urged directors and their companies to "actively participate in this concept release, because we really do need to hear from you."

Schapiro noted that the Commission is also reevaluating all of its corporate filing forms and disclosure requirements, asking whether the information being sought is still relevant, or whether another type of information or a different form of presentation would be more meaningful to investors and the markets.

Given the demands that financial regulatory reform legislation will likely impose on the agency's rulemaking agenda, she noted that it may be "a while" before a proposal is presented to the Commission.

However, Schapiro the staff is already reviewing existing disclosure requirements that haven't been updated, reviewing recommendations made by previous advisory committees such as the Committee on Improvements to Financial Reporting and others, and asking the individuals who prepare and review disclosures day-in and day-out what rule-changes they think would elicit better information.

After the review, Schapiro said she expects the staff will present recommendations it can act on quickly, such as revising the risk disclosure requirements, as well as more sweeping measures that will take more time, such as possibly changing filing formats so that "basic information can be more easily digested by investors and updated by companies."

Noting that the staff will tackle the problem of "needless repetition in company filings," Schapiro said, "If you have suggestions for improving our disclosure requirements, we would love to hear from you."

Meanwhile, she noted that the Commission continues to encourage the convergence of U.S. GAAP and International Financial Reporting Standards, but acknowledged that bringing the two systems together has proven a challenging process.

"We believe that it's important to provide for adequate due process and commentary on new standards, in order to ensure the informational value, integrity and political independence of the final outcome," she said. "While we are committed to global standards, a key priority is and must be protecting investors in American markets. We are executing a comprehensive work plan, dedicating significant resources to it and providing periodic progress reports."

In written remarks, Schapiro also offered her view of a good example of risk disclosure under the SEC's revised rules.

"Investors are informed and reassured by a proxy statement that begins with...a thorough discussion of the risk-related responsibilities of the board and its various committees," she said. "It then adds a detailed narrative that touches on the company's reporting to the Board and its committees about credit and liquidity risks, risk-focused auditing strategies, and the impact on risk of compensation policies."

Schapiro contrasted that with a risk oversight disclosure statement that reads: "The board has risk oversight responsibility for Company X and administers this responsibility both directly and with assistance from its committees."

"Investors might find this type of statement informative - but perhaps not quite in the way that the company intended," she said.