Publications and Presentations
On February 12, 2025, the SEC’s Division of Corporation Finance (Division) issued Staff Legal Bulletin (SLB) No. 14M. SLB 14M provides guidance on the scope and application of Exchange Act Rules 14a-8(i)(5) and 14a-8(i)(7), which set forth two of the 13 bases upon which companies may exclude shareholder proposals from their proxy materials, as well as other aspects of the rules governing shareholder proposals. SLB 14M rescinds SLB 14L, which had made it more difficult for companies to exclude social policy and environmental shareholder proposals, even where such proposals had little significance to the relevant company, and reinstates prior guidance regarding how the 14a-8(i)(7) exclusion will be evaluated.
This Advisory summarizes the process for presidential appointments, including the paperwork nominees must complete before appointment or nomination, the Senate confirmation process, and services that can be provided by outside counsel to facilitate the intrusive vetting process and avoid mistakes.