Market Trends 2019/20: Staff Legal Bulletins No. 14I, 14J, and 14K and Other Shareholder Proposal Developments

This market trends practice note discusses Staff Legal Bulletin No. 14I, Staff Legal Bulletin No. 14J, and Staff Legal Bulletin No. 14K of the Division of Corporation Finance of the Securities and Exchange Commission (SEC), which provide guidance with respect to shareholder proposals submitted for inclusion in company proxy statements pursuant to Rule 14a-8 under the Securities Exchange Act of 1934 (Rule 14a-8). This note also describes changes in SEC procedures for processing shareholder proposal no-action requests, trends in shareholder proposals submitted for inclusion in proxy statements for the 2020 proxy season and proposed amendments to Rule 14a-8.