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IRS Circular 230 Disclosure: Unless we have specifically stated to the contrary in writing, any discussion of federal tax issues or submissions in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the United States federal tax laws or (2) promoting, marketing, or recommending to anyone any transaction or matter addressed herein.

Status of SEC Proxy Statement Rule Proposals

The SEC continues to examine potential new rules which may apply to 2010 proxy season. These include, among others, enhanced compensation disclosure and analysis (CD&A) requirements and enhanced disclosure regarding director qualifications. 

We expect the SEC to take action before the end of 2009 on some proposals which will impact the 2010 proxy season.  The SEC has already postponed action on proxy access until 2010 meaning that any new rules adopted would not be in effect for the 2010 proxy season.