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SEC Approves Enhanced Proxy Disclosures--What to do in Advance of Your 2010 Annual Meeting by Laura Badian
Arnold & Porter LLP - Washington Office
Richard E. Baltz
Arnold & Porter LLP - Washington Office
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December 28, 2009
Previously published on December 2009
On December 16, 2009, the US Securities and Exchange Commission (SEC) adopted “Proxy Disclosure Enhancements” about risk, compensation, and other corporate governance matters. The final rules are discussed in a 129-page adopting release and have an effective date of February 28, 2010. Despite the length of the final release and the complexity of the new disclosure requirements, the SEC failed to provide any phase-in period for compliance. In Compliance and Disclosure Interpretations posted on December 22, 2009, the SEC’s Division of Corporation Finance, in fact, accelerated the compliance date for some filers. The interpretations, among other things, provide for the following compliance schedule: www.arnoldporter.com
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