MEMORANDUM
To: | Public File
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From: | David G. Nason
Counsel to Commissioner Atkins
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Date: | December 2, 2003
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Re: | File No. S7-19-03
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On December 2, 2003, Commissioner Atkins and David Nason met with Ted White of Calpers to discuss the above-referenced matter.
The following general points were made by Mr. White:
- The triggers can be detrimental to corporate democracy, but understand that they are probably a necessary reality at this stage of the process.
- The triggers should be made more liberal to ease the shareholder community to utilize the mechanism.
- There is not an expectation that the rule will be formally utilized for many companies in the next few years.
- The Commission should consider a trigger that focuses on underperformance of a particular company.
- Various other technical comments about the mechanics of the proposal.
He indicated that Calpers intended to provide detailed comments through the comment letter process.
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