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Index Fund Enforcement Index Fund Enforcement Alexander I. Platt* Corporate America today is astonishingly beholden to three large financial institutions: BlackRock, Vanguard, and State Street Global Advisors. As investors have moved their money into low-cost, highly diversified investment vehicles known as index funds, the so-called “Big Three” institutional fund managers that dominate the index fund industry have grown rapidly and accumulated unprecedented economic power and influence. For instance, these three institutions now vote one out of every four shares of stock issued by large U.S. companies. Policymakers and scholars have begun to sound the alarm about this concentration of corporate ownership, and have proposed reforms to reduce or eliminate these institutions’ influence over portfolio companies. But concentrated power has its benefits, too. In this Article, I argue that the remarkable size, permanence, and cross-market scope of the Big Three’s ownership stakes gives them the capacity and, in some cases, the incentive to punish and deter fraud and misconduct by portfolio companies. Corporate governance and securities regulation scholars have argued that these institutions have generally overriding incentives to refrain from meaningful corporate stewardship, but the facts on the ground tell a somewhat different story. Drawing on a comprehensive review of the Big Three’s enforcement activities and interviews with key decision-makers for these institutions, I show how they have been using engagement, voting, and * Copyright © 2020 Alexander I. Platt. Climenko Fellow and Lecturer on Law, Harvard Law School. J.D. Yale Law School. For helpful comments, I thank Stephen Bainbridge, Lucian Bebchuk, John Coyle, Einer Elhauge, Elizabeth de Fontenay, Jesse Fried, Zachary Gubler, Scott Hirst, Howell Jackson, Reinier Kraakman, Da Lin, Ann Lipton, Peter Molk, John Morley, James Park, Menesh Patel, Holger Spamann, James Spindler, Urska Velikonja, David Zaring, participants in the Richmond Junior Faculty Workshop, the National Business Law Scholars Conference, the Harvard Corporate Law Faculty Workshop, the Harvard Law Corporate Fellows Workshop, the Southeastern Association of Law Schools Annual Conference, ClimenkoFest, the Corporate and Securities Litigation Workshop, and several anonymous inside and outside counsel for the Big Three. I also thank Elizabeth Ferrie for excellent research assistance, and Sophia Armstrong and her colleagues at the UC Davis Law Review for terrific editorial suggestions. 1453 1454 University of California, Davis [Vol. 53:1453 litigation to discipline culpable companies and managers. I also identify the “pro-enforcement” incentives that explain these actions. Policymakers and scholars are now engaging in a heated debate over indexation and the future of the Big Three. To date, however, participants have overlooked the potentially beneficial role these institutions may play in the enforcement ecosystem. This Article corrects this oversight, bringing Index Fund Enforcement into focus. Policymakers should embrace regulatory reforms designed to enhance Index Fund Enforcement, not weaken it. TABLE OF CONTENTS INTRODUCTION ................................................................................. 1455 I. THE RISE OF THE BIG THREE ................................................... 1464 A. Indexing 101 .................................................................... 1464 B. The Financial Benefits of Indexed Investing ..................... 1465 C. The Rise of the Big Three ................................................. 1466 II. THE TOOLS OF ENFORCEMENT-BASED STEWARDSHIP .............. 1469 A. Litigation ......................................................................... 1469 1. Fraud-on-the-Market (10b-5) Litigation ................. 1469 a. Doctrine .............................................................. 1469 b. Forms of Participation in 10b-5 Litigation ........... 1472 2. Foreign Litigation ..................................................... 1474 3. Litigation and Deterrence ......................................... 1474 B. Just Vote “No” ................................................................. 1479 C. Engagement ..................................................................... 1481 D. Guidance ......................................................................... 1482 III. DO THE BIG THREE HAVE A REASON TO CARE ABOUT CORPORATE MISCONDUCT? .................................................... 1482 A. Enforcement as Cost-Effective Stewardship ...................... 1484 B. Competing with Other Index Funds .................................. 1486 C. Competing with Non-Index Investment Vehicles ............... 1490 D. Reducing Systemic Risk ................................................... 1491 E. Reputational Concerns ..................................................... 1492 F. Beyond Index Funds ......................................................... 1494 G. Predicting the Big Three’s Enforcement Activity ............... 1495 IV. HOW DO THE BIG THREE RESPOND TO CORPORATE MISCONDUCT? ........................................................................ 1495 A. Litigation ......................................................................... 1498 B. Just Vote “No” ................................................................. 1503 C. Engagement ..................................................................... 1515 D. Guidance ......................................................................... 1517 E. Assessing the Evidence ..................................................... 1519 2020] Index Fund Enforcement 1455 V. IMPLICATIONS AND REFORMS .................................................. 1520 A. Weighing the Social Costs and Benefits of Index Funds .... 1520 B. Common Ownership ........................................................ 1522 C. Disclosure Reforms .......................................................... 1523 D. Litigation Reforms ........................................................... 1525 E. Private Reforms ............................................................... 1526 CONCLUSION..................................................................................... 1527 APPENDIX: BIG THREE PUBLICLY-DISCLOSED FOREIGN SHAREHOLDER LITIGATION (2014-2018) ....................................................... 1529 INTRODUCTION Three financial institutions now vote 25% of the stock in the largest U.S. public companies.1 The figure may soon be closer to 40%.2 Vanguard, BlackRock, and State Street Global Advisors (“SSGA”) — the so-called “Big Three” — dominate the market for the low-cost, highly diversified investment vehicles known as “index funds.” As more investors put their savings into these vehicles, these institutions have accumulated an unprecedented level of economic power. Policymakers and scholars have been working urgently to understand the social 1 See Lucian Bebchuk & Scott Hirst, The Specter of the Giant Three, 99 B.U. L. REV. 721, 724 (2019) [hereinafter Giant Three]. 2 See id. 1456 University of California, Davis [Vol. 53:1453 impact of this consolidation of ownership3 and what to do about it — up to and including breaking up the industry.4 To date, however, this debate has overlooked an area where the Big Three’s rise may have a particularly significant effect: the corporate enforcement ecosystem.5 On the one hand, the problem of corporate fraud might be ameliorated by a dramatic consolidation of shareholder power. The remarkable size, cross-market scope, and permanence of the Big Three’s ownership stakes could give them a unique capacity to overcome collective action problems and impose meaningful accountability and deterrence.6 On the other hand, the Big Three may 3 Scholars have debated what these developments mean for a broad range of economic and social issues. See, e.g., STEVEN D. BLEIBERG ET AL., THE IMPACT OF PASSIVE INVESTING ON MARKET EFFICIENCY, EPOCH PERSP., May 2017, at 1, https://www. wespath.com/assets/1/7/Epoch-The-Impact-of-Passive-Investing.pdf (market efficiency); Itzhak Ben-David et al., Do ETFs Increase Volatility?, 73 J. FIN. 2471 (2018) (systemic risk); Madison Condon, Externalities and the Common Owner, WASH. L. REV. (forthcoming 2019), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3378783 (climate change); Einer Elhauge, Horizontal Shareholding, 129 HARV. L. REV. 1267 (2016) [hereinafter Horizontal Shareholding] (competition); Dorothy S. Lund, The Case Against Passive Shareholder Voting, 43 J. CORP. L. 493 (2018) (corporate governance); John C. Coates, The Future of Corporate Governance Part I: The Problem of Twelve (Harvard Pub. Law, Working Paper No. 19-07, 2018), https://papers.ssrn.com/ sol3/papers.cfm?abstract_id=3247337 (inequality). Policymakers have given serious consideration to some of these concerns. E.g., Oversight of the Enforcement of the Antitrust Laws: Hearing Before the Subcomm. on Antitrust, Competition Policy, & Consumer Rights of the Comm. on the Judiciary, 114th Cong. (2016) (statement of Bill Baer, Assistant Att’y Gen. for Antitrust Division) (describing Department of Justice investigations into possible anticompetitive conduct linked to common ownership); COUNCIL OF ECON. ADVISERS ISSUE BRIEF, BENEFITS OF COMPETITION AND INDICATORS OF MARKET POWER 13-14 (2016), https://obamawhitehouse.archives.gov/ sites/default/files/page/files/20160502_competition_issue_brief_updated_cea.pdf [https://perma.cc/T8L4-5RTH] (calling for further research into the anticompetitive effects
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