Morrison Foerster partner Ryan Adams was featured as a guest speaker on CCRcorp’s Timely Takes Podcast recorded on Feb. 19, 2025. The podcast episode reviews the SEC Division of Corporation Finance Staff’s recent guidance on shareholder proposals in Staff Legal Bulletin No. 14M, and includes the following topics:
- Background on rescinded SLB 14L;
- The “ordinary business,” “micromanagement,” and “economic relevance” bases for exclusion following SLB 14M;
- Whether companies will continue to submit a “board analysis”;
- The significance of SLB 14M’s note that the 2022 proposed amendments to the “substantial implementation,” “duplication,” and “resubmission” bases for exclusion under 14a-8 have not been adopted;
- SLB 14M’s guidance on proof of ownership and deficiency letters; and
- What the timing of SLB 14M means for companies as they navigate this shareholder proposal season.
Listen to the podcast.