July 16, 2003

One surprising note in the

One surprising note in the aftermath of Corp Fin’s shareholder access report is the apparent speed by which the Commission appears ready to act – a proposal on the disclosure component sometime in August and a proposal on shareholder access to the ballot in September. See the Washington Post interview with SEC chair Donaldson at Obviously, the magnitude of the shareholder access proposal should persuade the Commission to allow a lengthy comment period after its proposing release is issued.

For subscribers, we have posted a list of 20 insider trading policies at