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The Corporate Counselor

September 2009

Proposed Changes to Disclosure Rules

Plan Now to Avoid the Unexpected

By Avrohom J. Kess, Francis C. Marinelli and LeAnn S. Leutner

On July 10, 2009, the Securities and Exchange Commission (SEC) released its proposals for a number of changes to the compensation disclosure and proxy rules. Many of the proposed changes do not seem dramatic at first glance, but they could lead to surprising results.

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