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ARTICLE · 26 OCTOBER 2010

The SEC's "Proxy Plumbing" Concept Release

Foley & Lardner LLP
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On July 14, 2010, the SEC issued its concept release on the U.S. proxy system, in which it raised numerous issues regarding the mechanics of U.S. proxy voting and solicitation, dubbed "proxy plumbing."

United StatesCorporate/Commercial Law
Foley & Lardner
Foley & Lardner
Mark Plichta
Mark Plichta
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On July 14, 2010, the SEC issued its concept release on the U.S. proxy system, in which it raised numerous issues regarding the mechanics of U.S. proxy voting and solicitation, dubbed "proxy plumbing." The concept release sought public comment on these issues in anticipation of potential future rulemaking by the SEC in three main areas:

  • Accuracy, transparency, and efficiency of the voting process, including over-voting and under-voting, confirmation of votes, proxy voting by institutional securities lenders, and proxy distribution fees
  • Communications and shareholder participation, including company communications with shareholders, facilitating retail investor participation in shareholder voting, and data-tagging proxy-related materials

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