How Corp Fin Might Review Shareholder Proposal No-Action Letters Under a New Administration

In this 19-minute video, Cooley’s Reid Hooper tackles what you need to know about the sea change that may be upon us under a new administration as he covers these “5 Quick Things”:

1. Staff Legal Bulletin 14L in the Crosshairs
2. Continued Strength of Rule 14a-8(i)(7) Micromanagement Arguments
3. Rule (i)(10) Substantial Implementation Arguments Make a Triumphant Return
4. Procedural Arguments Continue to Rule the Day – How Companies Can Adequately Preserve those Arguments
5. When Submitting No-Action Requests, Be Mindful of Staff Review Times

Authored by

Broc Romanek

Cooley