Insights
Client Alert
SEC Issues Formal Interpretation Regarding Proxy Unbundling Rule in Merger & Acquisition Transactions
October 20, 2004
Carl R. Sanchez, Deyan P. Spiridonov and Claudia Simon
On September 20, 2004, the SEC Division of Corporate Finance issued the fifth supplement to its Telephone Interpretations Manual, which provided specific interpretative guidance regarding the application of Rule 14a-4(a)(3) in the context of merger and acquisition transactions.