Disclosure as a Corporate Governance Tool: Channels & Challenges
Oxford Handbook of Corporate Law and Governance (2d ed.) (Jeffrey N. Gordon & Wolf-Georg Ringe eds., 2025)
Human Capital Disclosure & Corporate Governance: The New Evidence
46 Cardozo Law Review 485 (2024)
The Market-Essential Role of Corporate Climate Disclosure
56 U.C. Davis Law Review 2105 (2023)
The SEC’s Climate Disclosure Rule: Critiquing the Critics
50 Rutgers Law Record 101 (2022)
The Human Capital Management Movement in U.S. Corporate Law
95 Tulane Law Review 639 (2021)
Securities Disclosure as Soundbite: The Case of CEO Pay Ratios
60 Boston College Law Review 1123 (2019) (with Steven A. Bank)
Too Big to Disclose: Firm Size and Materiality Blindspots in Securities Regulation
64 UCLA Law Review 602 (2017)
Shorter Works
Blog Post: Disclosure as a Corporate Governance Tool: Channels & Challenges
Oxford Business Law Blog (July 27, 2026)
Blog Post: Justifying Sustainability Disclosure: Investor Demand vs. Market Efficiency
Oxford Business Law Blog (Feb. 22, 2024) · Expanded version in Columbia Law School Blue Sky Blog (Mar. 1, 2024)
Climate Change, West Virginia v. EPA, and the SEC’s Distinctive Statutory Mandate
Administrative & Regulatory Law News (Aug. 2022) (with Jill Fisch, Donna Nagy & Cynthia Williams)
Blog Post: The SEC’s New Proposal on Climate Disclosure: Critiquing the Critics
Oxford Business Law Blog (Mar. 29, 2022)
Blog Post: The Growing Global Appeal of CEO Pay Ratios and Lessons from the U.S. Experience
Oxford Business Law Blog (Feb. 27, 2019) (with Steven A. Bank)
Blog Post: Securities Disclosure as Soundbite
Columbia Law School Blue Sky Blog (Feb. 11, 2019) (with Steven A. Bank)
Comments & Testimony
Comment Letter to the SEC re: Enhancement of Emerging Growth Company Accommodations and Simplification of Filer Status for Reporting Companies
July 22, 2026
Invited Testimony, U.S. Senate Climate Change Task Force, Discussion on the SEC’s Climate-Related Disclosure Rule
June 12, 2024 · Invited testimony
Invited Testimony, U.S. House Committee on Financial Services, Subcommittee on Oversight & Investigations, Hearing on the SEC’s Climate-Related Disclosure Rule for Investors
January 18, 2024 · Invited testimony
Comment Letter to the SEC re: SEC’s Authority to Promulgate Climate-Related Disclosure
June 6, 2022 (with Jill Fisch, Donna Nagy & Cynthia Williams)
Comment Letter to the SEC re: Proposed Rule on “Pay-Versus-Performance” Disclosure
March 4, 2022
Comment Letter to the SEC re: Rulemaking Petition on Workforce Investment Disclosure
July 6, 2022
Comment Letter to the SEC re: Climate Change and Other ESG Disclosure (including Human Capital Management)