SEC Returns To Individual Written Response Policy For Proxy Requests

SEC staff determined that individualized written responses to proxy requests for no-action relief provide better clarity and transparency to shareholders and companies as to compliance with Securities Exchange Act Rule 14a-8 ("Shareholder Proposals").

In an announcement reconsidering staff responses to Rule 14a-8 no action requests, staff stated it had reconsidered its 2019 decision to discontinue individualized responses. After an evaluation of recent staff responses to certain proxy requests utilizing a website chart instead of through individual written letters, the staff decided to return to providing individualized written responses to such requests. SEC staff will post their response letters on the Division's website in a "timely manner." Staff stated it will also publish a chart of all responses at the close of each proxy season.