This client memo, courtesy of our relationship with Proxy Analytics, updates the firm’s prior insights on the disposition of no-action requests subject to the SEC staff’s new approach to managing such requests based on the firm’s analysis of no-action letters submitted through January 31 as posted on the SEC’s landing page through February 13. The memo provides an overview of the number and mix of submissions compared to prior years, stated grounds for exclusion, and exclusion trends season-over-season.