Further to our recent report: "Corp Fin Staff Clarifies Certain Aspects of Shareholder Proposal Guidance," Weil's "Heads Up for the 2018 Proxy Season: Tips from the SEC Staff on Applying the New Board Analysis Element in Requesting Shareholder Proposal No-Action Relief" summarizes clarifications and guidance on the new shareholder proposal guidance (SLB 14I) imparted by SEC Corp Fin Senior Special Counsel Matt McNair at the ABA Business Law Section Fall Meeting on November 17th. While the tips for applying the new guidance appear generally consistent with the information he shared previously, many certainly are not obvious takeaways from the SLB itself, and thus are worth reviewing for purposes of gleaning additional information, color, and context (particularly as respects Staff's expectations of the board's role and input) that may facilitate the no-action request process.
See also "New Shareholder Proposal Guidance: Apple Takes the Plunge" in Proxy Season here, and numerous additional resources on our Shareholder Proposals topical page.This post first appeared in last week's Society Alert!