Proxy access remains a hot issue in 2016, with the New York City Comptroller announcing that it has targeted 72 public companies with proposals, following a successful 2015 campaign. Institutional investor Vanguard also recently announced its general guidelines for voting on proxy access proposals. While Vanguard says that it will continue to take a case-by-case approach, it indicates a preference for proxy access by a shareholder or group holding three percent of the stock for three years, rather than an ownership threshold of five percent as announced early last year. The ownership threshold cited by Vanguard is consistent with the New York City Comptroller’s proposal, although the guidelines differ from the proposal on other points. In addition, the SEC does not appear to view a proxy access shareholder proposal to be “substantially implemented” by a company unless the company’s proposal contains a three precent ownership threshold. See Vanguard’s voting guidelines and an analysis of 18 SEC no-action responses to “substantially implemented” requests.