On November 17, 2021, the Securities and Exchange Commission adopted rules mandating universal proxy cards in contested director elections. The new rules will require issuers and dissidents to use proxy cards that list the names of both the issuer’s and dissident’s nominees, allowing shareholders to select among all nominees in a manner designed to more closely mirror in-person voting practices. In addition, the new rules require dissidents to solicit holders of a minimum of 67 percent of the voting power of shares entitled to vote in the election. The new rules also establish notice, filing and presentation requirements when using a universal proxy card. The new rules are scheduled to take effect for contested elections after August 31, 2022.