Cooley's new post: "In no-action letters, staff looks at Rule 14a-8(i)(7) exception and executive comp" examines a handful of recent Rule 14a-8(i)(7) (ordinary business exception) no-action requests and SEC Staff responses to provide insight into how the still new'ish SLB No. 14J - specifically as respects proposals that: (i) address senior executive and/or director compensation and ordinary business matters, (ii) address senior executive and/or director compensation that are also available or applicable to the general workforce, and (iii) micromanage senior executive and/or director compensation practices - is being applied in practice. While each no-action request is highly facts & circumstances-dependent, the accounts are nevertheless instructive as to Staff's evaluations of the various considerations raised by issuers on recurring proposal topics.
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Access additional resources on our Shareholder Proposals page. This post first appeared in the weekly Society Alert!
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