Articles
Making Sense Of SEC’s NOBO-OBO Rules
Published in Law360
February 19, 2010
The debate over proxy mechanics has focused on the desire of issuers to have more direct channels of communication with their retail shareholders, and a dissatisfaction with the Securities and Exchange Commission’s "NOBO-OBO" rules. This article responds to some of the questions that have arisen regarding these rules and the somewhat complicated regulatory context for communicating with retail shareholders.