November 9, 2012

Survey Results: Delegation of Authority

Here are survey results on delegation of authority practices:

1. Who is responsible for managing your company's delegation of approval authority process?
- Corporate secretary's office - 25.0%
- Legal department - 27.5%
- Individual business units are responsible for managing their own process - 12.5%
- Finance - 30.0%
- Other - 5.0%

2. On what does your company base its delegation of authority structure?
- Monetary thresholds - 90.0%
-Transaction type (e.g. acquisition, capital expenditure, procurement, etc.) - 70.0%
- Strategic impact - 0%
- Business risk - 15.0%
-Time/resource commitment - 2.5%
- Other non-monetary considerations - 7.5%

3. Which best describes your company's approach to delegation of authority?
- We have a single policy that uniformly applies to the parent company and subsidiaries - 57.5%
- We have a single policy with unique thresholds for the parent and/or particular subsidiaries - 25.0%
- We do not have a single policy and separately address delegation of authority at each subsidiary - 10.0%
- Not applicable as our company isn't structured into parent and subsidiaries - 5.0%
- Other - 2.5%

Please take a moment to participate in this "Quick Survey on Rules of Order for Board Meetings & Annual Meetings" and this "Quick Survey on Conflict Minerals."

September-October Issue of "The Corporate Counsel"

Last week, we wrapped up the September-October Issue of The Corporate Counsel and it includes pieces on:

- JOBS Act Update: SEC Proposes the General Solicitation Changes to Rule 506
- The Rule 144 Aggregation Tail--Donees' Sales Don't Affect Affiliate's Form 144 Filing Obligation
-Three-Month Form 144 Look-Back Includes Sales Covered by Prior Form 144
- Standing in the Affiliate's Shoes--Our Interpretive Request
- 2012 Year-end Tax Tip for Gifts of Stock and Other Charitable Giving
- Say-on-Pay Litigation 2.0
- The Staff's Annual SLAB on Shareholder Proposals
- Nasdaq Research Keeps Getting Easier (and Better)
- Compensation Consultant Fee Disclosure--"Additional Services" Include Those Rendered to Compensation Committee
- Farewell to XBRL Limited Liability for LAFs

Act Now: Get this issue for free when you try a 2013 No-Risk Trial today.

- Broc Romanek