Securities and Corporate Governance

• Change in RiskMetrics Policy on OP Units in Evaluating Options Plans - 12/12/08

• NAREIT Comments on SEC's Proposed Rule on Form S-3 Eligibility Requirements That Would Restrict UPREIT Debt Issuances - 9/5/08

• NAREIT Comments on NASAA Proposal Regarding Direct Participation Programs - 12/7/06

• NAREIT Comments on the SEC Concept Release Concerning Management's Reports on Internal Control Over Financial Reporting - 09/21/06

• NAREIT Comments on the SEC Securities Reformed Proposal - 01/31/05

• NAREIT Comments on the SEC Proposed Rule on Temporary Postponement of the Final Phase-In Period for Acceleration of Periodic Report Filing Dates - 09/14/04

• Submission to the SEC on Security Holder Director Nominations - 12/22/03

• Financial Reporting Alert: SEC Staff Clarifies Guidance on FFO Reporting - 7/7/03

• Financial Reporting Alert: SEC Staff Issues Guidance on FFO Reporting - 6/20/03

• Submission to the SEC on Rule 10b-18 - 2/18/03

• Submission to the SEC on Standards Relating to Listed Company Audit Committees - 2/18/03

• SEC Rule Retains Use of Non-GAAP Per Share Measures - 1/16/03

• NAREIT Submission to the SEC on Conditions for Use of Non-GAAP Financial Measures - 12/16/02  

• NAREIT Submission to the SEC on Management Discussion and Analysis About Off-Balance Sheet Arrangements - 12/09/02

• NAREIT Submission to the SEC Regarding Disclosures Required by the Sarbanes-Oxley Act of 2002 - 11/26/02

• NAREIT Submission to the SEC on Improper Influence on Conduct of Audits - 11/25/02  

• 8-K SEC filing - 8/26/02

• Letter to the SEC on CEO/CFO Certifications - 8/14/02

• NAREIT Submission to the NYSE on Corporate Governance - 7/16/02

• NAREIT Submission to the SEC on Critical Accounting Issues - 7/19/02

• SEC Critical Accounting Issues - 7/19/02

• NAREIT Submission to the SEC on 8-K Proposed Rule - 6/24/02

• NAREIT Letter to the Securities and Exchange Commission on Acceleration of Periodic Report Filing Dates and Disclosure Concerning Website Access to Reports - 5/23/02

• Comment Letter on Proposed Selective Disclosure and Insider Trading Rules - 5/2/00

• Executive Summary, SEC Proposed Rule, "Selective Disclosure and Insider Trading"

• Audit Committee Comment Letter to SEC - 12/13/99

• Aircraft Carrier Comment Letter to SEC- 8/12/99  

• Comment Letter on M & A Release- 4/09/99  

• Summary of Aircraft Carrier Release- 3/05/99