Historical Shareholder Engagement Practices Put Under Microscope due to Mid-Proxy Season Guidance From SEC
Cooley special counsel Reid Hooper and Justin Kisner published an article in The Review of Securities & Commodities Regulation analyzing the US Securities and Exchange Commission’s mid-proxy season update to compliance and disclosure interpretations, which aimed to clarify when shareholder engagement might shift from Schedule 13G to Schedule 13D reporting. Hooper and Kisner evaluate responses to this updated guidance, market reactions and strategic adjustments for navigating the remainder of the 2025 proxy season and beyond.
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