Schedule 14A
Please expand your discussion to address how the experience of the Lead Independent Trust Manager is brought to bear in connection with your board’s role in risk oversight.
On behalf of Camden Property Trust, we acknowledge receipt of the comment letter of the Staff of the United States Securities and Exchange Commission dated August 31, 2022 (the “Staff Letter”) with regard to the above-referenced proxy statement. We confirm we will revise our future proxy disclosures to address the applicable topics discussed in the Staff Letter as well as any material development to our risk oversight structure. We acknowledge we and our management are responsible for the accuracy and adequacy of our disclosures notwithstanding any review, comments, actions or absence of action by the Staff. One letter for all the questions, without numbered answers. Read the reply ↗
Please expand upon the role that your Lead Independent Trust Manager plays in the leadership of the board. For example, please enhance your disclosure to address whether or not your Lead Independent Trust Manager may: • require board consideration of, and/or override your CEO on, any risk matters; or • provide input on design of the board itself.
See the reply above.
Please expand upon how your board administers its risk oversight function. For example, please disclose: • how you apply different oversight standards based upon the immediacy of the risk assessed; • whether you consult with outside advisors and experts to anticipate future threats and trends, and how often you re-assess your risk environment; • whether you have a Chief Compliance Officer and to whom this positionRest of the question
reports; and • how your risk oversight process aligns with your disclosure controls and procedures.
See the reply above.
Also in this review: closing letter, 2022-10-20