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In the adopting release for the new Marketing Rule, the SEC stated that it would be withdrawing various No Action Letters (NALs) superseded by the new rule. In October, the Commission finally issued Information Update 2020-10 formally withdrawing those NALs. In total, 203 NALs are being either withdrawn or modified.
Remember that comments become publicComments become part of the public domain once submitted and resolved. Comments and the related responses are posted to the SECs website no earlier than 20 days after the review is completed or the registration statement is declared effective.
On August 25, 2010, the SEC adopted Rule 14a-11, mandating proxy access at all public companies. Any shareholder or shareholder group that held more than 3% of a public companys shares for more than 3 years would be eligible to nominate candidates for up to 25% of the companys board seats (the Rule 14a-11 Formula).
No-action letters are available in the following sources: Federal Securities Law Reporter. SEC website - Division of Corporation Finance No-Action, Interpretive and Exemptive Letters. Lexis. Westlaw.
SEC Form DEF 14A, also called a definitive proxy statement, is intended to furnish security holders with adequate information to be able to vote confidently at an upcoming shareholders meeting. Form DEF 14A is most commonly used with an annual meeting proxy and filed in advance of a companys annual meeting.
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A no-action letter is a letter written by the staff members of a government agency, requested by an entity subject to regulation by that agency, indicating that the staff will not recommend that the agency take legal action against the entity, should the entity engage in a course of action proposed by the entity
Rule 14a-8 of the Securities Exchange Act of 1934 provides a framework allowing a public company shareholder to request that a proposal be included in the companys proxy statement, to be voted upon at a companys shareholder meeting.
Rule 14a-8 of the Securities Exchange Act of 1934 provides a framework allowing a public company shareholder to request that a proposal be included in the companys proxy statement, to be voted upon at a companys shareholder meeting.
Since 1947, no-action letters under Securities and Exchange Commission (SEC) Rule 14a-8 have allowed SEC staff members to regulate shareholder voice upon managements request, acting as intermediaries between shareholders and management on matters related to shareholder proposals.
You can find a compilation of Staff No Action, Interpretive, and Exemptive Letters from the Divisions of Corporation Finance, Investment Management, and Trading and Markets, and the Office of the Chief Accountant in the Staff Interpretations section of our website.

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