If the shareholder is not a record owner, the shareholder must submit a written statement as to his beneficial ownership from the record holder of the securities. In an earlier Staff Legal Bulletin (SLB 14F), the Division of Corporation Finance stated that only securities intermediaries that are participants in the Depositary Trust Company (DTC) could be viewed as "record holders" and therefore a beneficial owner must obtain a proof of ownership letter from the DTC participant through which the securities are held. SLB 14G expands this interpretation to provide that proof of ownership letters from entities that are affiliates of DTC participants can also meet the requisite proof of ownership standard. SLB 14G also addresses the manner in which a company must notify a shareholder proponent if it views that the proponent failed to follow one of the eligibility or procedural requirements under Rule 14a-8.