On September 6, 2019, the Division of Corporation Finance (Division) of the US Securities and Exchange Commission (SEC) announced1 a significant change to its process with respect to reviewing no-action requests submitted to the Division pursuant to Rule 14a-8 promulgated under the Securities Exchange Act of 1934, as amended. The Division said it changed the policy to allow the staff to focus “on how it could most efficiently and effectively provide guidance.”
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