SEC Guides On Tackling Shareholder Proposals

Corporate Secretary

Brian V. Breheny Marc S. Gerber Richard J. Grossman

In October 2018, the SEC Division of Corporation Finance published Staff Legal Bulletin No. 14J, which provides guidance concerning shareholder proposals. The bulletin addresses, among other topics, board analyses that may be provided in the context of certain “ordinary business” or “relevance” no-action requests, and the “micromanagement” prong of the “ordinary business” exclusion.