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Shareholder Proposals Securities Exchange Act of 1934 Proxy Materials

Cooley LLP

Five Mistakes Made With Preliminary Proxy Statements (Part 2)

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Following up on Part 1 of this blog that explains what a “preliminary proxy” is – and the first two common mistakes made with them – here are three more common mistakes (as well as a bonus note):...more

McGuireWoods LLP

SEC Announces Change to the Division of Corporation Finance’s Role in Rule 14a-8 No-Action Letter Process for the 2025-2026 Proxy...

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The U.S. Securities and Exchange Commission’s (SEC’s) Division of Corporation Finance announced on Nov. 17, 2025, that it will not issue Exchange Act Rule 14a-8 no-action letters to companies seeking to exclude shareholder...more

Baker Botts L.L.P.

SEC to Defer to Companies Excluding Most Rule 14a-8 Shareholder Proposals This Proxy Season

Baker Botts L.L.P. on

The Securities and Exchange Commission (the “SEC”) has announced that, for the 2025–2026 proxy season, it will not provide substantive responses to company no-action requests to exclude shareholder proposals under Rule 14a-8,...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

Cooley LLP

Corp Fin Posts First “Reasonable Basis” Rule 14a-8(j) Notice (For a Pending No-Action Request)

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Earlier this week, Corp Fin issued this statement saying that it won’t respond to no-action requests – at least until September 30, 2026 – unless a company is seeking relief under Rule 14a-8(i)(1). ...more

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