Amendment to S-K 403(b)  8.29.06

• New disclosure requirement
• Requires footnote disclosure of the number of shares pledged as security by named executive officers, directors and director nominees
• SEC considers this to be material information for investors

• pledging of shares as collateral subjects shares to risk and may influence management's conduct
• pledged shares may be subject to material risk or contingencies that do not apply to other shares

• Final release commentary  Rel 33-8732A IV

Rule

Provide information about beneficial ownership of management

• Tabular format

Beneficial ownership defined

• By reference to Regulation 13D rules
• See Beneficial Ownership Reporting

Instructions

S-K Item 403 Interpretations

• General 403(b) Interpretations
• Specific 403(b) Interpretations

• Issued 3.14.07
• Replace prior S-K 403 interpretations in July 1997 Manual of Publicly Available Telephone Interpretations and its March 1999 supplement
• See S-K 403 Interpretations

Law Firm Commentary

• Perkins Coie reference chart  3.20.07

10-K

Schedule 14A

Form 10

S-1

S-4

S-11

S-K Index