Analysis of New SEC Interpretations of Exchange Act Sections 13(d) and 13(g)

The staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “SEC”) published, on Sept. 14, 2009, its Compliance and Disclosure Interpretations (“CDIs”) relating to Sections 13(d) and 13(g) under the Securities Exchange Act of 1934 (the “Exchange Act”) . These CDIs replace the prior interpretations relating to Sections 13(d) and 13(g) contained in the July 1997 Manual of Publicly Available Telephone Interpretations. The CDIs are in question-and-answer format and include both previous interpretations and new guidance from the SEC.