Tuesday, October 16, 2012
The SEC's Division of Corporation Finance posted on the SEC website Staff Legal Bulletin No. 14G (CF) on Shareholder Proposals. It describes the purpose of the bulletin:
This bulletin is part of a continuing effort by the Division to provide guidance on important issues arising under Exchange Act Rule 14a-8. Specifically, this bulletin contains information regarding:
the parties that can provide proof of ownership under Rule 14a-8(b)(2)(i) for purposes of verifying whether a beneficial owner is eligible to submit a proposal under Rule 14a-8;
the manner in which companies should notify proponents of a failure to provide proof of ownership for the one-year period required under Rule 14a-8(b)(1); and
the use of website references in proposals and supporting statements.