Five Observations on Recent Use of Universal Proxies

On September 5, 2019, the SEC's Investor Advisory Committee (IAC) approved a recommendation that the SEC adopt its proposed universal proxy rule with modest changes to address objections that have been raised to the proposed rule.

While it is too early to tell if the IAC's recommendation will be the catalyst the SEC needs to dust off the universal proxy proposing release, the following observations from recent use of universal proxies may influence the approach the SEC ultimately takes to implement a universal proxy rule.

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