DragonGC reported (request here) on no-action request and response trends for the past four proxy seasons ended mid-May 2025.
Most notably:
- The number of no-action requests for the 2024/25 season (361) is up 33% compared to the 2023/24 season (272) and up nearly 100% compared to the 2022/2023 season, with each prior season based on meetings scheduled between July 1 and June 30.
- No-action request grants increased from 51.8% last season and from just 28.2% in the 2021/2022 season to 56.8% this season to date.
Bases for exclusions granted this season compared to last season are detailed here:
Notably, as shown above, exclusions under Rule 14a-8(i)(7) (ordinary business) increased from 58 last season to 85 this season, which Dragon GC attributes to the issuance of SEC Staff Legal Bulletin No. 14M.