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Shareholder Proposals Securities Regulation Disclosure Requirements

Jones Day

SEC Outlines 2026 Disclosure Reform Priorities

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Through recent speeches and other public statements, Chairman Paul Atkins of the Securities and Exchange Commission (the "SEC") and Director James Moloney of the Division of Corporation Finance reiterated that significant...more

Cooley LLP

Corp Fin Director Jim Moloney Highlights Upcoming Attractions

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If you’ve been reading this blog on a regular basis, you know that the SEC – including Corp Fin – has has been very active over the past year announcing a number of rulemaking and initiatives to come....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

McGuireWoods LLP

McGuireWoods Quarterly Securities & Capital Markets Update

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Welcome to the inaugural McGuireWoods’ Quarterly Securities & Capital Markets Update. Each edition will review important securities law developments from the previous quarter and alert readers of significant considerations...more

Cooley LLP

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

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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 is seeking relief under Rule 14a-8(i)(1), the “not a...more

Cooley LLP

Going Public? Know These Seven SEC Priorities for 2026

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As companies gear up for 2026, what happens at the SEC could smooth the path for public capital raising efforts. However, with “lessons learned” from the government-wide shutdown still fresh in our memories – and becoming...more

BCLP

SEC Announces It Will Not Review Most 14A-8 Shareholder Proposal No-action Letters for Next Proxy Season

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On November 17, 2025, the Division of Corporation Finance staff of the SEC (“Division”) announced that, due to resource constraints...more

Carlton Fields

SEC Chairman’s “Make IPOs Great Again” Project

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On October 9, SEC Chairman Paul Atkins delivered the keynote address at the John L. Weinberg Center for Corporate Governance’s 25th Anniversary Gala, providing details about what he calls his project to “make initial public...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

Jones Day

SEC Says It's a "New Day": A New Agenda and New Leadership

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On September 4, 2025, the Securities and Exchange Commission ("SEC") released its Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions (the "Agenda"), providing insight into the SEC's rulemaking priorities under...more

Carlton Fields

SEC Spring 2025 Rulemaking Agenda Reveals the Agency’s Top Rulemaking Priorities

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The Securities and Exchange Commission’s (SEC) Spring 2025 rulemaking agenda was released on September 4, 2025, offering insight into the SEC’s rulemaking priorities under Chair Paul Atkins. In a concurrent statement, Atkins...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

Vinson & Elkins LLP

Texas Hold ‘Em: New Law Requires Proxy Advisors to Show Their Cards if “Nonpecuniary” Factors Guide Voting Recommendations -...

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On June 20, 2025, Texas Governor Greg Abbott signed Senate Bill 2337 (“SB 2337”), a novel regulation that will require significant disclosure obligations for proxy advisors, such as ISS and Glass Lewis, for their voting...more

Jones Day

SEC Withdraws Proposed ESG Disclosure and Shareholder Submission Rules

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In a significant but not unsurprising policy shift, the U.S. Securities and Exchange Commission (SEC) has announced the withdrawal of proposed rules aimed at enhancing ESG disclosures and modifying shareholder proposal...more

Cooley LLP

Capital Markets Update – April 2025 One-Minute Reads

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Nasdaq policy recommendations - On March 31, Nasdaq announced the release of a comprehensive set of policy recommendations in a paper titled, “Advancing the U.S. Public Markets: Unlocking Capital Formation for a Stronger...more

Cooley LLP

Five Wild Things About the New Texas Shareholder Proposal Law

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As we’ve blogged about recently, Texas has taken a number of steps to bolster its reputation as a business-friendly state. The latest is a new law aimed at making it harder for shareholder proponents to get a proposal (other...more

Mayer Brown

SEC Staff Issues Legal Bulletin Announcing Changes to Shareholder Proposal Review Process During the 2025 Proxy Season

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On February 12, 2025, the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) issued Staff Legal Bulletin No. 14M (“SLB 14M”), which rescinds in part...more

Cohen & Gresser LLP

A New Chapter for the SEC: A Philosophical Shift on Shareholder Engagement, Shareholder Proposals, and ESG

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Only a short time has elapsed since President Trump named Mark T. Uyeda as Acting Chair of the Securities and Exchange Commission (“SEC”) on January 21, 2025. Already, however, the regulatory climate has shifted significantly...more

BCLP

SEC Reinstates Shareholder Proposal Guidance Rescinded Under Chairman Gensler

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In one of its first actions under the new Administration, the SEC staff issued new guidance that largely reinstated older guidance that had supported the ability of public companies to exclude shareholder proposals from their...more

Alston & Bird

SEC Publishes New Guidance on the “Economic Relevance” and “Ordinary Business” Shareholder Proposal Exclusions and Updated...

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Our Securities Group examines the Securities and Exchange Commission’s new guidance on the “economic relevance” and “ordinary business” exclusions for shareholder proposals....more

Cooley LLP

Corp Fin does a one-eighty on shareholder proposals under Rule 14a-8

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In June 2023, then-Commissioner Mark Uyeda (currently, Acting Chair) spoke to the Society for Corporate Governance 2023 National Conference on the topic of shareholder proposals under Rule 14a-8. Alluding to the frequent...more

Keating Muething & Klekamp PLL

Proxy Season Update: SEC Restores Case-by-Case Approach for Shareholder Proposal Exclusions

Public companies navigating the 2025 proxy season just got some breathing room—at least when it comes to excluding certain shareholder proposals. Last week, the Staff of the SEC’s Division of Corporation Finance—in a...more

Wilson Sonsini Goodrich & Rosati

Everything Old Is New Again for Shareholder Proposals: SEC Division of Corporation Finance Issues Staff Legal Bulletin No. 14M

On February 12, 2025, the U.S. Securities and Exchange Commission (the Commission) Division of Corporation Finance staff (the staff) issued Staff Legal Bulletin No. 14M (SLB 14M) to provide informal guidance on shareholder...more

Morrison & Foerster LLP

Back to the Future: SEC Staff Issues Sweeping New Guidance on Shareholder Proposals Mid-Season

On February 12, 2025, the Division of Corporation Finance (Staff) of the U.S. Securities and Exchange Commission (SEC) published Staff Legal Bulletin No. 14M (SLB 14M), rescinding Staff Legal Bulletin No. 14L (Nov. 3, 2021)...more

Goodwin

SEC Outlook: Potential Updates Under Nominated Chairman Atkins

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The SEC currently has several notable rule proposals that have received public comment but have not yet been finalized. The potential direction of these proposals is likely to be influenced by the leadership of the new SEC...more

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