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No-Action Letter Trends

By Randi Morrison posted 06-06-2024 06:59 PM

  

DragonGC reported on year-over-year no action request and response trends. 

Most notably:

  • The number of no-action requests for the 2023/24 season (276) is up 50% compared to the 2022/23 season (184), but up just ~15% compared to the 2021/22 season (241), with each season based on meetings scheduled between July 1 and June 30.
  • No-action request grants are up 6% this season (52%) compared to the 2022/23 season (46%).

Bases for exclusions granted this season compared to last season are detailed here:

Notably, as shown above, exclusions under Rule 14a-8(i)(2) (violation of law) and Rule 14a-8(i)(7) (ordinary business) increased fairly dramatically season-over-season, with the latter representing 40% of all exclusions.

Access additional resources on our Proxy & Annual Reporting Season 2024 page.

                   This content first appeared in the Society Alert!

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