RegAlert2018-03-27
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SEC Division of Investment Management staff letter: Dividend and Income Fund— Omission of Shareholder Proposal Submitted by Matisse Capital
The staff of the Division of Investment Management confirms it will not recommend enforcement action to the Securities and Exchange Commission if Dividend and Income Fund omits a shareholder proposal submitted by Matisse Capital from its 2018 proxy materials. This determination relies on Rule 14a-8(e)(2) under the Securities Exchange Act of 1934, based on the finding that the Fund received the proposal after the applicable submission deadline. The staff's informal advice does not adjudicate the merits of the exclusion or preclude the proponent from pursuing rights in court.
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Securities Exchange Act of 1934 — Rule 14a-8 Dividend and Income Fund
March 27, 2018
Pamela M. Krill, Esquire Godfrey & Kahn, S.C. One East Main Street, Suite 500 Madison, Wisconsin 53701-2719
Dividend and Income Fund Omission of Shareholder Proposal Submitted by Matisse Capital
Dear Ms. Krill:
In a letter dated February 20, 2018, on behalf of Dividend and Income Fund. (the “Fund”), you requested confirmation from the staff of the Division of Investment Management that it would not recommend enforcement action to the Securities and Exchange Commission if a stockholder proposal (the “Proposal”) submitted by Matisse Capital on behalf of Matisse Discounted Closed-End Fund Strategy, is omitted from the joint proxy materials for the Fund’s 2018 annual meeting of stockholders.
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Source: Securities and Exchange Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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