News & Analysis as of

Rule 14a-8

Seward & Kissel LLP

The SEC Puts Precatory Proposals on the Chopping Block

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The SEC Chairman indicates a policy shift for public companies, inviting them to take action to exclude precatory shareholder proposals from their proxy materials. In a recent keynote address at the Weinberg Center for...more

Cooley LLP

Microsoft Excludes Chevedden Proposal on Procedural Grounds Without No-Action Relief (Due to Shutdown)

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As a byproduct of the government shutdown, Microsoft has decided to exclude a shareholder proposal submitted by John Chevedden on the grounds that it wasn’t submitted timely – even though the company hasn’t received no-action...more

BCLP

Shareholder Proposal Strategies During Government Shutdown Or Post-shutdown Bottleneck

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Last month, Microsoft announced it excluded a shareholder proposal from frequent shareholder proponent John Chevedeen before receiving no-action relief from the SEC. The company had submitted a routine no-action letter...more

Cooley LLP

Deciphering Rule 14a-8 and SEC Chairman Atkins’ Recent Remarks: What is ‘Precatory,’ and How Might It Affect Your...

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If you follow legal news, you’ve no doubt seen the many alerts, blogs and articles with splashy headlines about Rule 14a-8 of the Securities Exchange Act of 1934. Although corporate governance counsel will generally take the...more

Wilson Sonsini Goodrich & Rosati

SEC Chairman Addresses Potential Reforms Relating to Shareholder Proposals and Shareholder Litigation

On October 9, 2025, Chairman Paul S. Atkins of the U.S. Securities and Exchange Commission (SEC) gave a much-publicized keynote address at the University of Delaware’s John L. Weinberg Center for Corporate Governance. In the...more

DLA Piper

SEC Signals Potentially Significant Changes to Rule 14a-8 Shareholder Proposal Process

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On October 9, 2025, during a keynote address at the John L. Weinberg Center for Corporate Governance’s 25th Anniversary Gala, United States Securities and Exchange Commission (SEC) Chairman Paul Atkins suggested that the SEC...more

Venable LLP

Responding to Shareholder-Approved Precatory Proposals

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While 2025 saw a decrease, shareholders continue to submit precatory proposals under the Security and Exchange Commission’s (“SEC”) Proxy Rule 14a-8 for consideration at public company annual meetings, and these proposals...more

Cooley LLP

Proxy Season Highlights, Part Two: What the 2025 No-Action Letter Landscape Tells Us About Preparing for 2026

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The 2025 proxy season marked a turning point in the Securities and Exchange Commission’s (SEC) administration of shareholder proposals. ...more

Cooley LLP

Will Lack of Shareholder Proposals Mean More ‘Vote No’ Campaigns? Maybe It Already Has…

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I’ve blogged a few times about how the SEC Chairman Paul Atkins has delivered a speech in which he stated that one of his top priorities is to make being a public company an attractive proposition, with eliminating precatory...more

Jones Day

Preparing for an Evolving Shareholder Proposal Landscape

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This White Paper examines how recent commentary from U.S. Securities and Exchange Commission Chairman Paul Atkins signals a greater role for state law in defining shareholders’ ability to place proposals on company proxy...more

Fenwick & West LLP

SEC Chair Suggests Major Potential Changes for the Proxy Proposal Process

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In recent prepared remarks, U.S. Securities and Exchange Commission (SEC) Chair Paul S. Atkins laid out his priorities for the SEC, including efforts to make operating as a public company attractive to more businesses....more

Cooley LLP

SEC Chairman Suggests Path to Eliminating Most Shareholder Proposals

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In remarks delivered on October 9 at the John L. Weinberg Center for Corporate Governance’s 25th Anniversary Gala, US Securities and Exchange Commission (SEC) Chairman Paul Atkins suggested the SEC may be open to eliminating...more

Morrison & Foerster LLP

SEC Chairman Atkins Casts Doubt on the Validity of Precatory Shareholder Proposals

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On October 9, 2025, in remarks at the University of Delaware’s Weinberg Center for Corporate Governance, U.S. Securities and Exchange (SEC, or the “Commission”) Chairman Paul S. Atkins spoke of what he described as “three...more

Cooley LLP

SEC Chair Atkins Speech Could Spell Death Knell for Non-Binding Shareholder Proposals

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In a bombshell speech last night, SEC Chair Paul Atkins stated that one of his top priorities is to make being a public company an attractive proposition – and he noted that these are the three primary obstacles...more

Fenwick & West LLP

Securities Law Update - October 2025

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

Cooley LLP

What the SEC’s Shutdown Means for You

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Last week, I blogged that if a shutdown happens, it feels like it could last longer than the typical shutdown given the politics involved. The shutdown is now here – and Corp Fin posted this note late yesterday afternoon...more

Skadden, Arps, Slate, Meagher & Flom LLP

Shareholder Proposal No-Action Requests in the 2025 Proxy Season: A Continuing Surge in Requests and a Favorable Regulatory...

Rule 14a-8 under the Securities Exchange Act of 1934 permits shareholders with relatively nominal shareholdings to submit proposals to companies for inclusion in the companies’ proxy statements. These are to be voted on by...more

Morrison & Foerster LLP

A Season of Change: Shareholder Proposals During the 2025 Proxy Season

During each annual proxy “season,” companies receive and respond to shareholder proposals and often attempt to exclude these proposals from their proxy statements through no-action requests submitted to the U.S. Securities...more

Ropes & Gray LLP

Unpacking a Busy Last Week for US ESG Disclosure and Compliance

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Hearings, rulings and speeches, oh my (to paraphrase and with apologies to The Wizard of Oz). During the back half of last week, there were “anti-ESG” hearings in the House of Representatives on shareholder proposals and...more

Jackson Walker

New Texas Law Applicable to “Nationally Listed Corporations” Sets Forth Heightened Requirements for Shareholder Proposals

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Texas Senate Bill 1057, which became effective September 1, 2025, adds new Section 21.373 to the Texas Business Organizations Code (“TBOC”). This new Section of the TBOC creates a framework that governs when and how...more

Mayer Brown Free Writings + Perspectives

SEC Releases Spring 2025 Rulemaking Agenda

On September 4, 2025, the Securities and Exchange Commission’s spring 2025 rulemaking agenda (the “Agenda”) was made publicly available (see here).  Chairman Paul Atkins previewed the Agenda, which widely diverges from the...more

Cooley LLP

What the 2025 No-Action Letter Landscape Tells Us About Preparing for 2026

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The 2025 proxy season marked a turning point in the Securities and Exchange Commission’s (SEC) administration of shareholder proposals. Over the course of the season, the staff of the Division of Corporation Finance (staff)...more

Morrison & Foerster LLP

Above Board: 2025 Proxy Season Recap

In this episode of the Above Board podcast, host Scott Lesmes is joined by Morrison Foerster partner and former SEC Division of Corporation Finance staffer Ryan Adams to recap major trends from the 2025 proxy season. They...more

Fenwick & West LLP

Securities Law Update - July 2025

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

Ropes & Gray LLP

SEC Reverses Course on Gensler-Era Rule Proposals – Withdraws Proposed Amendment to its Shareholder Proposal Rule

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In a broad reversal of course on proposed rules issued by the Securities and Exchange Commission (SEC) under the leadership of former SEC Chair Gary Gensler, on June 12, 2025, the SEC issued a notice withdrawing 14 of the...more

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