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No-Action Letter Request
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If a company intends to exclude a shareholder proposal from its proxy materials on procedural or substantive grounds, it must submit its reasons for doing so to the SEC, with a copy sent simultaneously to the shareholder proponent. This submission is referred to as a no-action letter request, and must be submitted to the SEC no later than 80 calendar days prior to filing the company's definitive proxy statement. Whether the company is ultimately able to exclude the proposal from its proxy statement will depend on the SEC's response to the request.
Created By:
Russell Benasaraf
03-18-2014
Last Updated By:
Russell Benasaraf
03-18-2014
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