There is still time to submit responses to Glass Lewis’s 2024 Policy Survey, which the proxy advisor uses to gauge investor and other stakeholder interests and market sentiment. Since Glass Lewis selects the questions, the policy survey also indicates the advisor’s areas of policy focus. In this blog post, we identify a few highlights from the Executive Compensation portion of the survey we think practitioners should be tracking.

In early August, the U.S. Department of Justice (DOJ) entered a consent decree with Legends Hospitality Parent Holdings, LLC (“Legends”) to resolve gun-jumping allegations that Legends improperly exerted operational control over ASM Global, Inc. (ASM) while its HSR filing for its acquisition of ASM remained pending. Although the DOJ allowed the transaction to close, Legends agreed to pay $3.5 million and be subject to seven years of DOJ oversight to resolve the allegations. This action by the DOJ provides a reminder to buyers and sellers of the need to continue operating independently after a deal is signed until closing even when the deal does not present significant antitrust concerns.