SEC Updates Compliance & Disclosure Interpretations on Proxy Rules

On May 11, 2018, the SEC’s Division of Corporation Finance issued Compliance and Disclosure Interpretations (CDIs) on the proxy rules and related Schedules 14A/C. The C&DIs made clarifications and addressed a number of issues, including proxy disclosures needed to allow proxy holders to exercise their discretionary authority, matters requiring filing of a preliminary proxy statement or disclosure of financial information, and disclosures in the New Plan Benefits Table and about incumbent directors.