Simpson Thacher Urges Caution with Respect to the SEC’s New Proxy Access Proposal
The Firm submitted comments to the SEC relating to its proposed proxy access rules in the form of (i) a letter submitted on behalf of the Firm questioning whether the evidence to support proxy access is sufficiently compelling to justify such a groundbreaking change at this time and (ii) a letter jointly prepared with six other law firms recommending that the SEC not adopt Proposed Rule 14a-11 and addressing a significant number of workability issues should that recommendation be rejected.