Search results for "SEC no-action "

SEC Release S7-23-19 Comments Due Today

SEC Release Comments Due Today

…rs. For example, when the SEC receives a no-action request from outside counsel, how do the Staff know outside counsel is authorized to represent the company for this specific shareholder proposal? 18. Are the informational requirements we are proposi…

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July 2009 News Archives

…e has a better dispute resolution, since no-action letters would likely be appealed to federal courts, which take a great deal more time to render decisions. The letter discusses the move away from plurality voting toward majority voting. “This trend…

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Proven Shareowner Action Formulas

Shareowner Action Handbook

…SEC Guidance (Staff Legal Bulletins) SEC No-Action Letters Reconsideration Guidance from Law Firms to Issuers (& Cal Bar search) Winning Change the World by Changing the Rules Networking Voting Help Getting Started Those just getting started in corpor…

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October 2004

…Wachtell lawyer wrote, in the so-called no-action letter to the division. In the past, SEC lawyers have shown a willingness to allow such non-binding resolutions, as long as they are precisely drafted to mirror the agency’s original proposal. But acc…

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File No. S7-23-19: By the Numbers - Source ISS

File No. S7-23-19 by the Questions

…rs. For example, when the SEC receives a no-action request from outside counsel, how do the Staff know outside counsel is authorized to represent the company for this specific shareholder proposal? 18. Are the informational requirements we are proposi…

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Rescind No-Action Policy

Rescind No-Action Policy

Investors ask SEC to rescind no-action policy recently announced. Additional resources and commentary regarding the new SEC No-Action Policy are included below the letter. Click for PDF. Letter Asking SEC to Rescind No-Action Policy Via Hand Delivery…

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July 2008

…er. No Action Letters The SEC posted the no-action letters relating to Rule 14a-8 that it processed during the recent proxy season. These letters include any responses provided by the Staff after January 1st of this year (and incoming request going ba…

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Shareholder Proposal Reform

Shareholder Proposal Reform Rebutted

…related to the corporation, by granting no-action letters. Then came the ‘ordinary business rule,’ allowing exclusion of proposals concerned with day-to-day business decisions, followed by other exclusions. The proxy was transformed from the equivale…

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February 2002

…as is now the case. In what is called “a no-action letter,” SEC staff essentially sent a Valentine’s Day (2/14/03) card to shareholders saying, essentially, shareholders can go to hell. Zucker said AFSCME plans to appeal the staff decision to the full…

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SEC: Time To Remove the Gag

…porations they own. The Commission has a no-action process for adjudicating disputes. If a corporation feels justified in excluding a proposal from its proxy materials, it can approach the Commission for a “no-action” letter. If issued, a no-action le…

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Deal Professor Envisions Corporate Gadfly

Gadfly Proposals Reduce Value?

…oon as the SEC disapproves the company’s no-action request, since a proposal from a gadfly is likely to reduce the company’s value. Even though their intent is primarily to show why managers generally oppose proposals, that is the takeaway investment…

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Verbal No-Action Decisions - SEC Lost Its Head

Verbal No-Action Decisions Questioned

…ammed by Shareholder Rights Group Verbal no-action decisions by the SEC threaten the integrity of corporate governance. On September 6, the Securities and Exchange Commission issued a new policy providing for verbal no-action decisions that could sign…

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Reform No-Action Process

Reform No-Action Process

Reform No-Action Process Reform no-action process. That was the call of a recent letter by the Shareholder Rights Group to John Coates in his new role as Acting Director of the SEC’s Division of Corporation Finance. The letter is posted below. Some f…

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No-Action Letters in Question

…ies appealed to the SEC and were granted no-action letters… the SEC would take no action if the companies left the proposals off their proxies. Now Monks says the SEC should get out of the business of reviewing proposal since “its bureaucracy has ofte…

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December 2005

…der offers, appraisal rights, derivative actions, direct actions, the history of claims under the securities acts, serving as lead plaintiff, and bondholder rights. The best book in this category up until now has been Craig MacKenzie’s The Shareholder…

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The Shareholder Action Guide

The Shareholder Action Guide

…d takeaways from reading The Shareholder Action Guide. Shareholder Action: Advocacy I found Behar’s discussion of the term ‘shareholder advocacy’ interesting. I used to call myself an editor, then a publisher, based on my identification as a blogger….

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March 2002

…ter is also a defendant. The 327 federal securities class action litigation suits filed in 2001 represent a 60% increase over the number of filings in 2000, and the companies sued lost a total of more than $2 trillion in market capitalization during t…

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Archives: September 1999

…copy of the shareholder proposal, QSI’s no-action request, Lawndale’s response and the SEC decision see QSII 13-D/A #11 Exhibits B-E athttp://www.sec.gov/Archives/edgar/data/708818/0001012870-99-002051.txt) The settlement has incorporated what may be…

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