On November 17, 2025, the SEC’s Division of Corporation Finance announced that it will largely refrain from issuing responses to company requests to exclude shareholder proposals under Exchange Act Rule 14a-8—except where exclusion is sought on the basis that the proposal is not a proper subject for shareholder action under state law (Rule 14a-8(i)(1)). Our recent Client Alert discusses this announcement including its implications for companies during the upcoming proxy season, October 1, 2025 through September 30, 2026.