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Shareholders CDIs

Fenwick & West LLP

SEC Updates CDIs on Schedules 13D and 13G Eligibility

Fenwick & West LLP on

The SEC published updated Compliance and Disclosure Interpretations on the filing of Schedules 13D and 13G/Shareholder Engagement....more

Cooley LLP

Vanguard Also Resumes Shareholder Engagements

Cooley LLP on

As expected when we heard that BlackRock had resumed shareholder engagements shortly after it paused them in the wake of Corp Fin’s new CDI positions regarding “control” and “influencing” a company when engaging, Vanguard...more

Wilson Sonsini Goodrich & Rosati

Corp Fin Updates CDIs on Beneficial Ownership Reporting

On February 11, 2025, the SEC’s Division of Corporation Finance (Corp Fin) updated its Compliance and Disclosure Interpretations (CDIs) relating to Regulation 13D-G beneficial ownership reporting by revising Question 103.11...more

BCLP

Time to Get Ready for the 2024 Reporting Season

BCLP on

As companies look ahead to the upcoming proxy and annual report season, the SEC has generated a number of new items to add to your compliance checklist – in addition to those covered in last year's list. Those items, along...more

Cooley LLP

Corp Fin posts new CDIs regarding the use of universal proxy cards

Cooley LLP on

Corp Fin has issued three new CDIs regarding universal proxy. In November 2021, the SEC amended the federal proxy rules to mandate the use of universal proxies in all non-exempt solicitations in connection with contested...more

Cooley LLP

Corp Fin issues new CDIs on universal proxy

Cooley LLP on

At the end of last week, Corp Fin issued three new CDIs related to universal proxies under Rule 14a-19. In November 2021, the SEC amended the federal proxy rules to mandate the use of universal proxies in all non-exempt...more

Cooley LLP

Blog: Staff provides a bit of relief regarding compliance with Disclosure Update and Simplification

Cooley LLP on

You may have noticed that there’s still no effective date for the new Disclosure Update and Simplification, which was adopted in August. The new amendments are scheduled to become effective 30 days after publication in the...more

Cooley LLP

Blog: Corp Fin issues two new CDIs on Notices of Exempt Solicitation

Cooley LLP on

Corp Fin has issued two new CDIs related to the voluntary submission of Notices of Exempt Solicitation under Exchange Act Rule 14a-6(g). That rule requires any person who engages in an exempt solicitation pursuant to Exchange...more

Cooley LLP

Blog: Corp Fin Issues Revised CDI Regarding Disclosure About Selling Shareholder Entities

Cooley LLP on

Last week, Corp Fin revised a CDI regarding disclosure about selling shareholder entities and withdrew another CDI on the same topic. The revised CDI (140.02) expands on the nature of the disclosure required under Reg...more

Dorsey & Whitney LLP

Can a shareholder who is unable to rely on the HSR passive investor exemption still file a Schedule 13G? Maybe, says the SEC Staff...

Dorsey & Whitney LLP on

On July 12, 2016, the US Department of Justice announced a record $11 million fine against an activist investment firm for improperly claiming an exemption from Hart-Scott-Rodino’s notification and waiting period provisions...more

Cooley LLP

Blog: Corp Fin Staff Issues New CDI On When Shareholder Efforts To Influence Management Affect Eligibility To Use Schedule 13G

Cooley LLP on

The Corp Fin staff continues to dribble out new CDIs, with the newest relating to circumstances when, under Rule 13d-1, shareholder efforts to influence management will affect the shareholder’s eligibility to use Schedule...more

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