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Dodd-Frank Act Hedging Policy Disclosures Begin
Shearman & Sterling LLP Link to more items from this source
July 11, 2019
"[I]ssuers other than smaller reporting companies and emerging growth companies must include the disclosure in proxy and information statements with respect to the election of directors during fiscal years beginning on or after July 1, 2019. For smaller reporting companies and emerging growth companies, compliance is required for fiscal years beginning on or after July 1, 2020."

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