On October 18th, the SEC published a staff legal bulletin providing the view of the Division of Corporation Finance regarding: (i) the types of brokers and banks that constitute "record" holders under Rule 14a-8(b)(2)(i) of the Securities Exchange Act of 1934 (the "Exchange Act") for purposes of verifying whether a beneficial owner is eligible to submit a proposal under Rule 14a-8; (ii) common errors shareholders can avoid when submitting proof of ownership to companies; (iii) the submission of revised shareholder proposals; (iv) procedures for withdrawing no-action requests regarding proposals submitted by multiple proponents; and (v) the Division of Corporation Finance's new process for transmitting Rule 14a-8 no-action responses by email. Staff Legal Bulletin No. 14F.