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SEC Issues Formal Interpretation Regarding Proxy Unbundling Rule in Merger & Acquisition Transactions

October 20, 2004

By 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.

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