Shareholders, CDIs, Corp Fin

Vanguard Also Resumes Shareholder Engagements

Cooley LLP on 3/10/2025

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

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

Cooley LLP on 12/9/2022

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

Corp Fin issues new CDIs on universal proxy

Cooley LLP on 8/31/2022

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

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

Cooley LLP on 8/2/2018

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

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

Cooley LLP on 8/2/2016

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

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

Cooley LLP on 7/15/2016

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