News & Analysis as of

Proxy Season

Vinson & Elkins LLP

When Short Sellers Attack

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A “short attack” is a campaign in which a short seller publishes a critical report about a target company in order to profit from the ensuing decline in the company’s share price....more

Cooley LLP

Broker Search: NYSE Aligned With Corp Fin on New CDI

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Recently, Corp Fin issued a slew of new and revised CDIs and New Question 133.02 states that Corp Fin recognizes that the “broker search” may be completed in less than 20 business days prior to record date....more

Proskauer - Employee Benefits & Executive...

ISS and Glass Lewis Release Compensation-Related Updates For 2026 Proxy Season

As part of their annual policy review cycles, Institutional Shareholder Services (“ISS”) and Glass Lewis & Co. (“Glass Lewis”) have released their compensation-related voting policy updates that will apply starting with the...more

Cooley LLP

Five Mistakes Made With Preliminary Proxy Statements (Part 1)

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With the partial federal government shutdown likely to close the SEC for only a day or two – see this new set of Corp Fin FAQs on the impact of a shutdown, which is essentially the same as the guidance from the last shutdown;...more

Goodwin

SEC Staff Reverses Position on Voluntary Notices of Exempt Solicitation

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The staff of the SEC’s Division of Corporation Finance has announced a significant policy shift in Proxy Rules Revised C&DI Question 126.06 regarding voluntary Notices of Exempt Solicitation under Exchange Act Rule 14a-103. ...more

Cooley LLP

Cooley’s 2025 Activism Retrospective

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Activists enjoyed a banner year in 2025. From proxy contest wins at blue-chip companies to a partnership with Taylor Swift’s fiancé, engaged shareholders once again demonstrated their capabilities, creativity and readiness....more

Foley Hoag LLP - Public Companies & the Law

SEC and Large Banks Continue Pushback on Proxy Advisers After JPMorgan

The Wall Street Journal is reporting that Wells Fargo has adjusted its approach to proxy voting and its use of proxy-advisory services, adding another high‑profile example to the growing trend of large financial institutions...more

Mayer Brown Free Writings + Perspectives

New and Revised CDIs on Proxy Rules, Exchange Offers and Tender Offers

On January 23, 2026, the Securities and Exchange Commission’s Division of Corporation Finance revised a number of Compliance and Disclosure Interpretations (“CDIs”) and issued several new CDIs.  The revised CDIs span...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Staff Issues New and Updated Compliance & Disclosure Interpretations

On January 23, 2026, the staff of the Securities and Exchange Commission’s (SEC’s) Division of Corporation Finance issued and updated a series of Compliance & Disclosure Interpretations (C&DIs), including on proxy rules,...more

K&L Gates LLP

Proxy Wars

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On 11 December 2025, President Trump issued a long-awaited executive order (EO) entitled “Protecting American Investors from Foreign-Owned and Politically-Motivated Proxy Advisors.” ...more

Cooley LLP

Corp Fin Revamps a Slew of CDIs (Including Objecting to Voluntary Exempt Solicitations on Form PX14A6G)

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Last Friday, Corp Fin revised nine CDIs, issued eight new CDIs – and withdrew ten CDIs. A huge shout out to Cooley’s Justin Kisner for the analysis of the CDIs below that are related to the proxy season and deals;...more

BCLP

Proxy Advisors Under Scrutiny: Regulatory And Legal Challenges Facing ISS And Glass Lewis

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As the climate for proxy advisors is becoming more turbulent, public companies may need to adjust their shareholder engagement strategies. ...more

Haynes Boone

Preparing for the Upcoming Form 10-K and Proxy Statement Season

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This alert highlights recent updates to Securities and Exchange Commission (SEC) disclosure obligations effective for the upcoming Form 10-K and proxy statement season as well as other regulatory updates companies should...more

Cooley LLP

Key Updates in BlackRock’s and Vanguard’s 2026 US Proxy Voting Guidelines

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BlackRock and Vanguard have released their proxy voting guidelines for the 2026 proxy season. This alert highlights the key updates in BlackRock Investment Stewardship’s (BIS) proxy voting guidelines for US securities and...more

Cooley LLP

ISS Updates Its FAQs to Align With ‘26 Proxy Guidelines

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Last month, I blogged several times about what ISS changed in its proxy voting guidelines for this proxy season. Now, ISS has updated its three sets of FAQs – consisting of Non-Compensation FAQs; Executive Compensation FAQs;...more

Maynard Nexsen

Public Company Advisory: SEC Snapshots Fourth Quarter 2025

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The members of Maynard Nexsen’s Public Company Advisory Practice counsel public companies and companies aiming to become public on the full range of matters shaping their governance and operation in the public markets. As a...more

Skadden, Arps, Slate, Meagher & Flom LLP

As Activism Becomes a Year-Round Sport, Possible Regulatory Changes Could Impact Both Activists and Companies

Despite geopolitical volatility, tariff policy uncertainty and a slower-than-expected M&A market in the first half of 2025, shareholder activism has not cooled. In fact, 2025 experienced another record year in the U.S. for...more

Perkins Coie

Preparing for the 2026 Public Company Reporting Season

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As public companies prepare for the 2026 reporting season, now is a good time to review and refresh last year’s disclosures. Key Takeaways - Public companies should anticipate significant changes in annual report...more

Fenwick & West LLP

Securities Law Update - January 2026

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Welcome to the latest edition of Fenwick’s Securities Law Update. This issue contains updates and important reminders on the following topics...more

Cooley LLP

Vanguard’s Updated Voting Policies: Seven Things to Know

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Last week, Vanguard updated its voting policies for this proxy season. Remember that Vanguard has split its stewardship teams into two – and for this proxy season, it appears there are no substantive differences between the...more

Katten Muchin Rosenman LLP

2026 Proxy Season Update: Key Regulatory and Market Developments

Overview - As public companies prepare for the 2026 proxy and annual reporting season, significant regulatory and market developments are shaping disclosure practices, governance and investor engagement. This update...more

Stikeman Elliott LLP

ISS and Glass Lewis 2026 Canadian Policy Updates

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Institutional Shareholder Services (“ISS”) and Glass Lewis have published their Canadian benchmark policy guidelines for the 2026 proxy season. This year’s updates include clarifying changes to ISS’ guidelines relating to...more

Cooley LLP

Shareholder Proposals: What Do the Exclusion Notices Look Like So Far? (UPDATED)

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Following up on last week’s blog about the stats on this: Ahead of this proxy season, Corp Fin issued this statement saying that it wouldn’t respond to no-action requests – at least until September 30, 2026 – unless a company...more

BakerHostetler

Preparing for the 2026 Proxy and Annual Reporting Season: Key Issues and Considerations

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For the 2026 proxy and annual reporting season, there are a number of key issues to consider as you begin to prepare your annual report and proxy statement. This article provides an overview of these issues and updates in...more

K&L Gates LLP

Preparing for Your 2025 Form 10-K and 2026 Proxy Season

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While the pace of amendments and rule changes from the US Securities and Exchange Commission (SEC) slowed in 2025 with the change in presidential administration and the appointment of new SEC Chair Paul S. Atkins...more

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