Jenner & Block

News Alert: New SEC Guidance on Shareholder Proposals

In this News Alert, Partners Jerry J. Burgdoerfer, William L. Tolbert and Elaine Wolff discuss SEC Staff Legal Bulletin No. 14E (the “SLB”) issued on October 27, 2009 regarding shareholder proposals and notification re: no-action requests.  Specifically the SLB deals with:

  • the application of Rule 14a-8(i)(7) to proposals relating to risk (e.g. environmental, financial or health risks);
  • the application of Rule 14a-8(i)(7) to proposals focusing on CEO succession planning; and
  • notification to the SEC regarding intent to submit a no-action request.