The Division of Corporation Finance issued Staff Legal Bulletin No. 14G which addresses shareholder proposals submitted in accordance with Rule 14a-8 under the Securities Exchange Act of 1934. The topics addressed in the bulletin are (1) 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 the Rule; (2) 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 (3) the use of website references in proposals and supporting statements.
Alert
October 23, 2012