TheCorporateCounsel.net

At a conference in San Diego today, Marty Dunn, Corp Fin Deputy Director, revealed that the staff already has received over 450 requests for no-action relief regarding shareholder proposals – which equals the near record amount received during all of last proxy season. At this rate – because February and March are very heavy months to process these requests – it appears that the staff might process more than 50% more than they have at any other time.

The SEC has posted the adopting release regarding attorney conduct – along with a second release seeking additional comments on the proposed noisy withdrawal provisions and an alternative approach.The adopting release is at http://www.sec.gov/rules/final/33-8185.htm – and the proposing release is at http://www.sec.gov/rules/proposed/33-8186.htm.