News & Analysis as of

Shareholder Proposals Shareholder Rights Securities Exchange Act of 1934

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

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

Cozen O'Connor

SEC Will Not Weigh in on Exclusion of Most Shareholder Proposals for Current Proxy Season

Cozen O'Connor on

On November 17, 2025, the SEC’s Division of Corporation Finance (the SEC) announced a significant change in its approach to no-action requests for public companies to exclude shareholder proposals under Exchange Act Rule...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

Seward & Kissel LLP

The SEC Puts Precatory Proposals on the Chopping Block

Seward & Kissel LLP on

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

Jackson Walker

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

Jackson Walker on

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

Thompson Coburn LLP

SEC proposes amendments to Rule 14a-8 that would enhance shareholders’ ability to add proposals to proxy statements

Thompson Coburn LLP on

The Securities and Exchange Commission (SEC) recently proposed three amendments to Rule 14a-8 under the Securities Exchange Act of 1934, which governs what proposals made by a public company’s shareholders must be included in...more

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