Four years after the SEC released its proxy plumbing concept release, the SEC Staff issued Staff Legal Bulletin #20 last night, which is in the format of 13 Q&As. The IM piece (Q&A #1-5) deals with the responsibilities of investment advisers to vote and hire proxy advisors. The Corp Fin piece (Q&A #6-13) deals with two exemptions from the proxy rules relied upon by proxy advisors. More to come tomorrow after the firm memos start rolling in. Thought this was gonna be a light week! And apparently so did everyone else because I haven’t seen any blog or law firm write this one up yet…
Internal Investigations: DC Circuit Restores Privilege Protections
In his blog, David Smyth lays out how the DC Circuit Court – In re: Kellogg Brown & Root – has overturned a lower court’s ruling to uphold the Upjohn principle that the attorney-client privilege protects confidential employee communications made during an internal investigation led by company lawyers. We are posting memos on this decision in our “Internal Investigations” Practice Area.
Our July Eminders is Posted!
– Broc Romanek