Proxy Access & “Substantially Implemented”: Corp Fin Rules on 18 Shareholder Proposals

February 16, 2016 On Friday, Corp Fin posted 18 no-action responses over proxy access shareholder proposals for which companies had argued they should be excluded under Rule 14a-8(i)(10) the substantially implemented basis. Looks like the Staff is favoring the 3% ownership threshold requirement as compared to other terms (egs. number of nominees, group […]