NOBO Update

Important changes to Non-Objecting Beneficial Owner (NOBO) request procedures:

On October 1, 2013, we introduced enhancements to the NOBO request process to simplify the process while further protecting sensitive data. These new procedures were developed after extensive discussions with Broadridge constituents and the Broadridge Steering Committee.

The below procedure will be effective for all NOBO requests with a record date on or after October 1, 2013. Any requests with a record date prior to this date will follow the previous process.

The following guidelines will be instituted to the NOBO request process for all issuers and third parties acting on behalf of their clients.

  • The NOBO request form has been simplified to include only those fields required under the new process. Effective October 1, 2013 this new request form will be the only version accepted by Broadridge and it must be signed by the Issuer. We strongly recommend that the information be typed using the online version to ensure all the information is legible and avoid unnecessary delays.
  • The attestation document must be signed by an officer of the company. To complete the attestation the document should be printed, preferably on corporate letterhead, and the signature must be notarized. Any document received without a notarized signature will not be processed. The attestation must be included with all NOBO requests.
  • Each request for NOBO data will require the submission of both forms in order to be considered in good order and processed. Incomplete requests will be returned to the requester and no action will be taken on the request. It is therefore important that both documents be fully completed and presented together.
  • IMPORTANT: Upon submission of a request in good order, the request will be processed and a letter containing an encryption password will be shipped via overnight delivery to the attention of the “Corporate Secretary” at the issuer’s corporate offices, identified by Edgar Online. Edgar serves as an independent, certified site. We have partnered with EDGAR Online, and have built a process to receive regular feeds from them containing corporate addresses. To avoid any delay in receiving this letter, please visit the SEC website to ensure the corporate address is correct. If any information requires correction, please refer to the SEC website for instructions, section 5.
  • This password will be used to access the NOBO data contained on the CD. This will be the only means of retrieving the password. The NOBO CD will be shipped separately to the shipping address requested on the NOBO request form. It will be the recipient’s responsibility to obtain the password from the issuer’s corporate secretary.

Should you have any questions regarding these procedural changes please feel free to contact Broadridge Client Services. *Please note, this procedure affects only US banks and brokers.

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