Expected Effective Date of Proxy Access Rules

By Cydney Posner

This Securities and Exchange Commission notice regarding intended Federal Register publication indicates that the new proxy access rules will be published in the Federal Register tomorrow, September 16. The rules become effective 60 days after publication, giving you an effective date of November 15, which means that companies that mailed their definitive proxy statements on or after March 15, 2010 will have a window period all or a portion of which will be open after the effective date of the new rules. For example, if a company mailed on Friday, March 12, its Rule 14a-11 window for its 2011 annual meeting would be October 13, 2010 to November 12, 2010, which precedes the effective date of the new rules, November 15, 2010.

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