New Compliance and Disclosure Interpretations

This week, the SEC’s Division of Corporation Finance updated its Compliance and Disclosure Interpretations (C&DIs) on various topics, including Proxy Statements and Schedule 14A, Securities Act rules, Regulation S-K, and Interactive Data. The updates include new questions related to universal proxies as well as the evaluation of whether a proxy statement proposal “involves” another matter and thus would trigger the need to include information about the other matter. Other C&DI updates address timing and disclosure of fee payments, links to Inline XBRL exhibits, references to specific information required to be provided in proxy statements, and calculation of the “10 calendar day” period in the proxy rules.