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"Ordinary Business" No-Action Requests: SEC Staff Weighs In

By Randi Morrison posted 03-31-2019 08:06 PM

  

Cooley's post: "Micromanagement? Significant policy issue? Staff no-action letters address Rule 14a-8(i)(7) exclusion" discusses several recent Rule 14a-8(i)(7) (ordinary business) SEC Staff no-action requests that yielded mixed results for issuers on trending proposals including climate change, mandatory employee arbitration, sexual harassment, allocation of Tax Act-triggered tax savings, and immigrant detention.

          See these prior reports: "Shareholder Proposals: SLB No. 14J In Action," "New Shareholder Proposal Guidance Addresses Board Analyses, Micromanagement," "Corp Fin Staff Clarifies Certain Aspects of Shareholder Proposal Guidance," and "Division of Corporation Finance Issues Staff Legal Bulletin on Rule 14a-8," and additional information & resources on our Shareholder Proposals page.

          This post first appeared in the weekly Society Alert!

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