CAHPTER 18
SETTING BOUNDARIES
As long-serving general counsel for Vanguard, Heidi Stam had a peculiar issue with the Securities and Exchange Commission. It was persistent, and there was not much she could do about it; she would have to learn to live with it. Her problem was simple, though ironic. While the SEC staff and commissioners often agreed with Vanguard’s drive to give the ordinary investor a fair break, to be candid in shareholder communications, and to reduce fees, they couldn’t always allow client-owned Vanguard to go forward with new initiatives because of the precedent it might set for other, traditionally organized fund companies. “Because Vanguard is so investor focused,” explained Stam, “its approach aligns very well with the ...
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