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Rule 134 And Suitability Disclosure

Recently, I came across the following Compliance and Disclosure Interpretation (C&DI) issued by the Division of Corporation Finance at the Securities and Exchange Commission: 510.04 Although suitability requirements are not permitted under a literal reading of Rule 134, Rule 134(a)(16) does permit the inclusion of “any statement or legend required by any state law or…

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CalPERS Focus List – “Oh, no one knows what goes on behind closed doors”

As I reported in this post from last November, the California Public Employees Retirement System has reworked its Focus List program.  According to this flow chart  published by CalPERS, the staff should have now completed its review of the top 500 U.S. based companies and selected 5-10 companies for what CalPERS calls “engagement”.  CalPERS’ revamped Focus List process raises significant concerns for…

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