Statement Commenting on the SEC’s Withdrawal from the No Action Process

Late last week, the SECʼs Division of Corporation Finance updated its Compliance and Disclosure Interpretations to advise that, going forward, the staff will object to using the SECʼs EDGAR filing platform to file Rule 14a-2(b) Notices of Exempt Solicitation by any shareholder holding less than $5 million in shares of the company to which the […]

The recent announcement by the SECʼs Division of Corporation Finance that its staff will not, during the 2026 proxy season, “… respond to no-action requests related to any basis for exclusion other than 14a-8(i)(1)” leaves both companies and investors in uncertain, uncharted waters. The lack of staff input deprives companies and proponents of an orderly […]

Authors Sehr Khaliq is the Director of Program Evaluation, and Timothy Smith is the Senior Policy Advisor at the Interfaith Center on Corporate Responsibility (ICCR). This post is based on their ICCR report. New York City Comptroller Brad Lander[i] recently urged three of the city’s pension funds to drop BlackRock, Fidelity, and PanAgora because of “inadequate” […]

On January 7, 2026, ICCR filed a Motion for Summary Judgment in its challenge against Texas statute SB 2337. ICCR’s suit, filed in federal court in November 2025 and joined by United Church Funds and Ceres, focused on a newly-adopted law that imposes unprecedented and burdensome unconstitutional obligations on ICCR and similarly-situated organizations. ICCR’s argument […]

The SEC’s recent announcement that the agency will be stepping back from responding to most No Action requests by companies this year is disturbing and disappointing. SEC leadership appears to be using the excuse of the government shutdown to give companies an open invitation to exclude any or all shareholder proposals from their proxies for […]