This week the SEC issued an update to some of the rules around shareholder proposals. While they don't change the current process substantially, they can trip up a careless investor, especially as we prepare resolutions for annual meetings in 2012.

Highlights include:

• Clarifying the documentation needed to demonstrate ownership of shares held in street name
• How companies will treat revisions to previously-submitted proposals.

Both updates could have the practical effect of adding a week or two to the time needed for an investor to put together documentation for a proposal for the annual meeting agenda.

In particular, the documentation update pertains to which firm, exactly, should attest to an investor's shareholdings when held in street name. Earlier, the SEC (in the Hain Celestial case) allowed an "introducing" broker to send the letter, whether or not that broker participates in the Depository Trust Corporation (DTC), the custodian of shares in the US. Now, a shareholder needs that letter from the DTC participant, if that's not the "introducing" broker. It could take extra time for your broker to get the requisite letter from their DTC correspondent.

If an investor needs to revise a previously-submitted proposal, they should do this before the corporation's deadline for submitting proposals. The SEC will allow companies to exclude revisions submitted after that deadline. This, too, means a shareholder should allow extra time for such revisions.

Diligent investors will of course submit proposals in plenty of time anyway, right?