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Shareholder Proposals Securities Exchange Act of 1934 No-Action Requests

Jones Day

Shareholder Proposal Litigation Increases Following the SEC's Revised Rule 14a-8 Process

Jones Day on

Since the SEC stopped substantively responding to Rule 14a-8 no-action requests, shareholders are increasingly turning to litigation to challenge the exclusion of their proposals from company proxy materials....more

Hogan Lovells

SEC Staff Suspends Substantive Responses to Most Shareholder Proposal No-Action Requests

Hogan Lovells on

On November 17, the SEC’s Division of Corporation Finance issued a statement announcing that it will play a reduced role in the shareholder proposal process under Exchange Act Rule 14a-8 during the 2025-2026 proxy season. ...more

Fenwick & West LLP

SEC Division of Corporation Finance Announces Streamlined Rule 14a-8 Process for 2025–2026 Proxy Season

Fenwick & West LLP on

The SEC’s Division of Corporation Finance has issued a statement outlining its new approach to handling shareholder proposal no-action requests under Exchange Act Rule 14a8 for the 2025–2026 proxy season....more

Vinson & Elkins LLP

No Action for No-Actions: SEC Announces Significant Change in No-Action Relief During the 2025-26 Proxy Season

Vinson & Elkins LLP on

On November 17, 2025, the Division of Corporation Finance (the “Division”) of the Securities and Exchange Commission (the “SEC”) announced it will not respond to, and will express no views on, requests for exclusions of...more

Ropes & Gray LLP

Shutdown Aftermath: SEC Staff to Consider Only Shareholder Proposal No-Action Requests Challenging Propriety of Proposals under...

Ropes & Gray LLP on

The Division of Corporation Finance (the “Division”) of the Securities and Exchange Commission (the “SEC”) released a statement today indicating that it will not respond to no-action requests by companies seeking to exclude...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

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