Shareholder Proposal No-Action Requests in the 2024 Proxy Season

Harvard Law School Forum on Corporate Governance

Marc S. Gerber

After two proxy seasons in which the SEC received and granted fewer no-action letters to exclude shareholder proposals, there was a surge in requests this year, and the SEC granted a higher percentage than in 2023. Partner Marc Gerber discusses how the results this season show that the no-action process remains a viable option for many companies to consider if they want to exclude inappropriate or deficient shareholder proposals.