SEC Staff Begins Taking Steps to Reform Shareholder Proposals

On November 1, 2017, the SEC Division of Corporation Finance released Staff Legal Bulletin No. 14I with new guidance on the shareholder proposal process. The guidance contemplates board involvement in seeking no-action relief under the ordinary business exception and economic relevance exclusions; establishes procedural requirements for proponents to designate representatives; and clarifies that shareholders and issuers may use images in proposals.