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Whole Foods No-Action Letters Mary Jo White

Cooley LLP

Blog: Corp Fin Issues New SLB Providing Guidance On Rule 14a-8 Exclusions For “Conflicting Proposals” And “Ordinary Business”

Cooley LLP on

Corp Fin today posted Staff Legal Bulletin 14H providing guidance on two key issues regarding shareholder proposals under Rule 14a-8: - the scope and application of Rule 14a-8(i)(9) (the exclusion for conflicting...more

Allen Matkins

Broad Coalition Delivers Blunt Rebuke To SEC Chairman

Allen Matkins on

Last month, I wrote that the SEC’s about face in responding to the no-action letter request of Whole Foods Market, Inc. “clearly wasn’t the SEC’s finest hour.” Several days later, a coalition of some 17 different...more

Proskauer Rose LLP

SEC Timeout on Proxy Access Issue Has Wider Implications

Proskauer Rose LLP on

On January 16, 2015, the SEC withdrew its December 1, 2014 no-action letter in which it concurred with the view of Whole Foods Market, Inc. that the company was entitled under SEC Rule 14a-8(i)(9) to exclude from its proxy...more

Blank Rome LLP

Withdrawal of Whole Foods No-Action Letter Leaves a Hole in Proxy Access Proposal Defense

Blank Rome LLP on

On January 16, 2015, the Securities and Exchange Commission (SEC) announced that, for the 2015 proxy season, the Division of Corporation Finance will not express any views as to whether a company may exclude a shareholder...more

Allen Matkins

The SEC’s Rule 14a-8 Process Just Became Even More Pointlessly Outré

Allen Matkins on

Yesterday, Broc Romanek posted on SEC Chair Mary Jo White’s Friday surprise with respect the no-action letter request submitted by Whole Foods Market, Inc. Readers may recall that in December Whole Foods had obtained the...more

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