Tag Archives | Rule 14a-8

Investor Response to Chamber - Don't Box Us In

Investor Response to Chamber: Don’t Gut Rights

Investor Response to Chamber: Letter Representatives of hundreds of investors with trillions of dollars in assets delivered a letter to the SEC on November 9, 2017, An Investor response to U.S. Chamber’s Proposal to Revise SEC Rule 14a-8 (report). We noted with interest the November 1, 2017, guidance contained in Staff Legal Bulletin No. 14I. […]

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Shareholder Proposal Reform

Shareholder Proposal Reform Rebutted

The U.S. Chamber of Commerce Center for Capital Markets Competitiveness (CCMC) released a paper on shareholder proposal reform, which contains a “set of recommendations for the SEC on fixing the broken Rule 14a-8 system in order to protect investors and make the public company model more attractive.” See also the Chamber’s press release, U.S. Chamber Offers Recommendations to […]

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Seal of SEC

“Directly Conflicts” Clarified by Staff Legal Bulletin

Never underestimate the ability of SEC staff to parse the rules in a creative way. Staff Legal Bulletin No. 14H (CF) does not adhere completely to original intent, which staff determined was “to prevent shareholders from using Rule 14a-8 to circumvent the proxy rules governing solicitations.” However, it gets us where we need to be in defining the […]

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USPX Updates Model Proxy Access Proposal

Two weeks after SEC lawyers granted six corporations approval to exclude “proxy access” proposals from their proxy materials, United States Proxy Exchange (USPX) members are already submitting an updated version of that same proposal to other corporations. Updated language addresses the flimsy pretexts for the lawyers’ decision, as well as implementing improvements to the proposal […]

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Webinar: Proxy Access Private Ordering under Rule 14a-8

Blank Rome LLP and Laurel Hill Advisory Group, LLC are hosting a complimentary webinar on Tuesday, October 18, 2011, at 12:00 pm EST to discuss how to prepare for the “private ordering” of proxy access under the amended provisions of Rule 14a-8. Full details can be found at the attached link. Numerous issues and questions […]

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Proxy Access Under Private Ordering: Advice of Counsel

myCorporateResource.com is a new database of law firm alerts, as well as providing many other resources. A great site worth exploring, which I have added to our blogroll. I encourage readers to go to the original documents linked below, since there you will get the clips in full context. My intent here is to simply […]

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Will the SEC Enforce Rule 14a-8?

The SEC has a reputation of enforcing regulations against two-bit players in the financial arena while tiptoeing around the big boys. Back in December, Apache Corp. (APA) announced plans to flaunt US securities laws. The Commission’s response has been three months of unbroken silence. Apache’s CEO, Stephen Farris, is somewhat of a crusader against Rule […]

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Free USPX Training – Learn How to File Shareowner Proposals

For a second year, the United States Proxy Exchange (USPX) is offering shareowners one-on-one training in the intricacies of filing shareowner proposals. The instructor will be a prominent shareowner activist who has successfully filed hundreds of shareowner proposals. The training is free for USPX members, and instruction is provided entirely by phone and e-mail. To […]

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