As reported in today's Society Alert, the SEC's Division of Corporation Finance just issued guidance in the form of this Staff Legal Bulletin on Rule 14a-8 concerning shareholder proposals.
Specifically, the bulletin contains information about the Division’s views on:
- the scope and application of Rule 14a-8(i)(7);
- the scope and application of Rule 14a-8(i)(5);
- proposals submitted on behalf of shareholders; and
- the use of graphs and images consistent with Rule 14a-8(d).
Watch this space and next week's Society Alert for commentary and analysis.
See also this new brief video from Ropes & Gray Securities & Governance Practice Chair & Society member Keith Higgins, wherein he suggested a series of modest, common sense shareholder proposal reforms, and our prior report: "Keith Higgins Suggests Modest Shareholder Proposal Reforms" in Proxy Season-Related Developments here.