Division of Corporation Finance Issues Small Entity Compliance Guide for E-Proxy
 
June 2, 2008
 

On May 22, 2008, the SEC issued a small entity compliance guide which summarizes the e-proxy rules. The guide also includes a table which compares some of the key differences between the notice only and the full set delivery options.

While the guide does not provide any new interpretive guidance, it is important for companies to review the guide. Pursuant to the Small Business Regulatory Enforcement Fairness Act of 1996, "in any civil or administrative action against a small entity for a violation occurring after the effective date of this section, the content of the small entity compliance guide may be considered as evidence of the reasonableness or appropriateness of any proposed fines, penalties or damages."

http://www.sec.gov/info/smallbus/secg/shareholderchoice-secg.htm