Cooley’s “Proxy Season Highlights, Part Two: What the 2025 No-Action Letter Landscape Tells Us About Preparing for 2026” recaps no-action statistics and trends based on requests submitted from December 1, 2024 – June 30, 2025. Of 371 total requests (compared to 274 in 2024 and 203 in 2023), 56% of 355 staff determinations granted relief, with further detail shown here:
The most successful bases for exclusion were:
The post includes a summary of the number of requests granted by each substantive and procedural basis for exclusion; how the numbers compare to 2024; and relevant commentary, as well as reminders for future submissions and observations about how 2026 may unfold.