Tag: Rule 14a-4(a)(3)

We identified our shareholder proposal on our proxy card as “Shareholder Proposal.” Does that work?

by Cydney Posner Uh, no.  In a new CDI, Corp Fin tells us how not to identify proposals on proxy cards, particularly shareholder proposals. Rule 14a-4(a)(3) requires that the form of proxy “identify clearly and impartially each separate matter intended to be acted upon.”  But, when it comes to shareholder […]

Corp Fin issues new CDIs on “unbundling” proposals in the M&A context

by Cydney Posner The SEC has posted new CDIs addressing the issue of “unbundling” of proxy proposals under Rule 14a-4(a)(3), which requires that the form of proxy “identify clearly and impartially each separate matter intended to be acted upon.” The focus of the new CDIs is unbundling of proposals in […]