Report on the Shareholder Communications Process with Street Name Holders, and the NOBO-OBO Mechanism - June 10, 2010

Katten Muchin Rosenman LLP
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Introduction and Executive Summary

The U.S. Securities and Exchange Commission (SEC) has announced that it intends to reexamine the system through which shareholders communicate with issuers and vote their shares. An important part of the shareholder voting and communications system services millions of street name shareholders each year, who hold their shares indirectly through brokers and bank custodians.

The members of the Securities Industry and Financial Markets Association (SIFMA)1 have a strong interest in ensuring that the shareholder communications and voting system continues to operate in a reliable, efficient and credible manner that serves the interest of their clients. Members also have an interest to ensure that important interests of their clients receive adequate protection, including the privacy rights of shareholders regarding the confidentiality of their personal information and trading decisions....

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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