On October 16, 2012, the SEC published another “Staff Legal Bulletin” with guidance on shareowner proposals submitted to public companies pursuant to Rule 14a-8. SLB No. 14G provides the Division of Finance’s views regarding: Proof of ownership under Rule 14a-8(b)(2)(i) for purposes of verifying whether a beneficial owner is eligible to submit a proposal; the manner […]
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SEC Abandons Celestial Reasoning, Divides Petition-Baby in Half
SEC Staff Legal Bulletin No. 14F (CF) finally addresses the issues of what is needed to evidence stock ownership for the purpose of filing a shareowner petition. It is obvious from first glance that shareowners whose broker or bank isn’t a DTC participant just got screwed. We will take the view going forward that, for […]
DTCC Splits Chair and CEO Positions
The company that holds legal title to about 80% of all American stocks announced this week that it will separate the role of chairman and chief executive officer following a two-year review of the organization’s governance. Splitting the roles will increase its oversight of risk management and follows a growing trend by international companies that […]
Who Should Submit Shareowner Proposals?
In Apache v. Chevedden, Apache’s court brief says: “When it comes to shareholder proposals, Apache is the ‘David’ and Chevedden is the ‘Goliath.’” That seems strange coming from a $33 billion market cap company. However, after reading their brief, I agree; the company seems to be at a disadvantage. They don’t seem to know how […]