SEC staff updates guidance on shareholder proposals

Author: Romeo Peter J.   Parrino Richard J.   Greenslade Kevin K.   Bahn C. Alex  

Publisher: Emerald Group Publishing Ltd

ISSN: 1528-5812

Source: Journal of Investment Compliance, Vol.13, Iss.1, 2012-04, pp. : 33-35

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Abstract

Purpose - The purpose of this paper is to explain the guidance on interpretive issues under Exchange Act Rule 14a-8 published in SEC Staff Legal Bulletin No. 14F (SLB 14F). Design/methodology/approach - The paper summarizes the guidance to companies provided by SLB 14F on how to verify a proponent's eligibility to submit a proposal, how to address submissions of revised proposals, and how to withdraw no-action requests for proposals with multiple proponents. Findings - SLB 14F is the staff's seventh legal bulletin on Rule 14a-8, which highlights the procedural and substantive complexities associated with shareholder proposals. Originality/value - The paper provides expert guidance from experienced financial services lawyers.