‘Tis A “Bootless Labour” To Ask The Staff To Appeal Its Own No-Action Advice
In This “Appeal” Of Whole Foods’ No-Action Letter Isn’t Very Appealing, I wrote about Jim McRitchie’s attempt to “appeal” the staff’s decision with respect to the exclusion of his proxy access proposal...
View ArticleSEC’s Rule 14a-8 Volte-Face Is Pointlessly Outré But It Does Have Real World...
Readers may recall that last December Whole Foods Market, Inc. had secured the SEC staff’s concurrence in excluding a shareholder access proposal submitted by Jim McRitchie. Then, SEC Chair Mary Jo...
View ArticleBroad Coalition Delivers Blunt Rebuke To SEC Chairman
Last month, I wrote that the SEC’s about face in responding to the no-action letter request of Whole Foods Market, Inc. “clearly wasn’t the SEC’s finest hour.” See SEC’s Rule 14a-8 Volte-Face Is...
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