CLIENT NEWSFLASH

Proxy Access Rules Effective November 15, 2010

September 16, 2010

The SEC’s new proxy access rules, announced on August 25, 2010, finally appeared in the Federal Register today, which means they will be effective as of November 15, 2010.  The 120-day notice period for Rule 14a-11 nominations means that the new rules will be available for the 2011 proxy season so long as a company’s most recent annual meeting proxy statement was mailed on or after March 15, 2010. Companies that qualify as ‘‘smaller reporting companies’’ are not subject to Rule 14a–11 until three years after the effective date.

Please click here to access commentary on the proxy access rules.

Please click here to access a summary of the proxy access rules.

 

If you have questions regarding this newsflash, please contact any of the lawyers listed below or your regular Davis Polk contact.

David L. Caplan212 450 4156david.caplan@davispolk.com
Ning Chiu212 450 4908ning.chiu@davispolk.com
William M. Kelly 650 752 2003 william.kelly@davispolk.com
Phillip R. Mills212 450 4618phillip.mills@davispolk.com
Richard J. Sandler212 450 4224richard.sandler@davispolk.com
Janice Brunner 212 450 4211janice.brunner@davispolk.com
Notice: This is a summary that we believe may be of interest to you for general information. It is not a full analysis of the matters presented and should not be relied upon as legal advice. If you would rather not receive these memoranda, please respond to this email and indicate that you would like to be removed from our distribution list. If you have any questions about the matters covered in this publication, the names and office locations of all of our partners appear on our website, davispolk.com.
© 2010 Davis Polk & Wardwell LLP