Analysis

SEC's Stance On No-Action Letters Raises Uncertainty

Law360 (September 12, 2019, 9:03 PM EDT) -- The U.S. Securities and Exchange Commission's policy that it may respond orally to no-action requests from companies seeking to exclude shareholder proposals from proxy statements — or decline to take a view — is creating widespread confusion, with some arguing it could hurt shareholders and others predicting a lack of precedent to guide companies.

The SEC on Sept. 6 said the policy change is intended to enable staff to focus on “how it could most efficiently and effectively provide guidance where appropriate.” Companies that want to exclude a shareholder proposal from their proxy materials — a frequent request each proxy season...

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