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Shareholder Proposals Securities Regulation Shareholder Rights

Cooley LLP

The Shareholder Proposal Exclusion Risk Is Real: Now Up to Three Lawsuits

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Last week, I blogged about how four NYC public pension funds sued a company in a New York federal court over its decision to exclude a workforce diversity shareholder proposal after the company decided it had a “reasonable...more

Cooley LLP

The Shareholder Proposal Exclusion Risk Is Real: The First Lawsuit

Cooley LLP on

Back when Corp Fin decided to bow out of serving as the referee for this proxy season, many preached that companies still had to be careful when deciding whether to exclude a proposal....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

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...

McGuireWoods LLP on

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

Cooley LLP

Glass Lewis Issues 2026 US Benchmark Policy Guidelines

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Glass Lewis has released its 2026 US Benchmark Policy Guidelines, which will apply to shareholder meetings held on or after January 1, 2026. Consistent with recent years, the updates are incremental rather than structural,...more

McDermott Will & Schulte

SEC steps back from the shareholder proposal game

McDermott Will & Schulte on

On November 17, 2025, the US Securities and Exchange Commission (SEC) Division of Corporation Finance announced that it will not respond to no-action requests by companies to exclude shareholder proposals for the 2026 proxy...more

Dorsey & Whitney LLP

SEC Fundamentally Alters the Shareholder Proposal Process for Upcoming Proxy Season

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The SEC’s Division of Corporation Finance recently issued a statement (the “Statement”) that, for the current proxy season, it will not respond to no-action requests for, and express no views on, companies’ exclusion of...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

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