Morrison & Foerster's "Shareholder Proposal No-Action Letters - 2018-2019 Review" reveals the firm's analysis of the 231 responses to no-action requests that SEC staff issued between October 1, 2018 and July 31, 2019, including the disposition of the requests, and the bases for and takeaways from staff's responses. On an overall basis, staff concurred with nearly 68% of requests for exclusion that were not withdrawn, with no-action grants most often citing Rule 14a-8(i)(10) and Rule 14a-8(i)(7). The key takeaways on page 2 are supported by relevant background and detail in the body of the report.
See also these prior reports: "SLB 14I & 14J: No-Actions Inform Future Requests," "Shareholder Proposal No-Action Letter Insights," and "Ordinary Business" No-Action Requests: SEC Staff Weighs In," and additional information & resources on our Shareholder Proposals page. This post first appeared in the weekly Society Alert!