In this post: “A (Very) Early Look at No Action Letters under Rule 14a-8,” Mayer Brown catalogues the current no-action requests posted on the SEC’s website by status and type with reference to the “reasonable basis to exclude” language provided in the SEC’s November 2025 statement regarding its reduced role in the Rule 14a-8 process. The average length of no-action request letters has declined from about 11 pages to six pages before and after, respectively, of the SEC’s statement.