Proxy Plumbing Concept Release – A Move Toward Proxy Process Reform?

After a unanimous vote at its June 14, 2010, open meeting, the Securities and Exchange Commission issued a Concept Release on the U.S. Proxy System (Release Nos. 34-62495; IA‑3052; IC‑29340), commonly referred to as the "proxy plumbing concept release." The Concept Release can be found at: http://www.sec.gov/rules/concept/2010/34-62495.pdf.

The Concept Release considers the proxy system as a whole, provides background on the current proxy distribution and voting process, and discusses the following three topics:

• Accuracy, transparency and efficiency of the voting process;
• Communications and shareholder participation; and
• Relationship between voting power and economic interest.