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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 http://www.washingtonpost.com/wp-dyn/articles/A61884-2003Jul15.html. Obviously, the magnitude of the shareholder access proposal should persuade the Commission to allow a lengthy comment period after its proposing release is issued.

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