There were 231 shareholder proposal no-action letter requests submitted to the SEC in the first half of 2017, compared with 218 proposals submitted for no-action letter relief during the same time period in 2016, according to Bloomberg Law data.
Proxy access bylaws continue to be the most popular shareholder proposal topic, with 50 proposals this year. Proposals related to human rights and social issues came in second at 44.
Interestingly, of the proposals related to environmental issues that were not withdrawn before SEC comment, SEC staff decided that 74 percent of them must be included in the company’s proxy materials. In contrast, for the other four most popular proposal topics, it was more likely than not that the SEC staff decided that the proposal may be excluded.
The Health Care, Financials, and Consumer Discretionary sectors all submitted 40 no-action letters each to the SEC. In the Financials sector, nine out of 40 no-action letters dealt with shareholder proposals relating to executive compensation. Seven of the 40 letters were requests regarding proxy access bylaws. In the Consumer Discretionary sector, 15 out of 40 letters were requests about human rights/social issues, and six were about proxy access bylaws. In the Health Care sector, 14 letters were requests about risk management. Eight of 40 letters were about proxy access bylaws.
Utilities, with 22, and Communications, with 20, rounded out the top five sectors with the most requests. Out of 22 no-action letter requests in the Utilities sector, 10 were related to environmental issues, and five were related to proxy access bylaws. In the Communications sector, six out of 20 requests related to human rights/social issues, and four were about proxy access bylaws.
Proxy access bylaws was the second most common shareholder proposal topic for each of the five top sectors.
For more data and analysis on the 2017 proxy season, Bloomberg Law subscribers can access our Proxy Season Analytics page on the Corporate Practice Center.
All Bloomberg BNA treatises are available on standing order, which ensures you will always receive the most current edition of the book or supplement of the title you have ordered from Bloomberg BNA’s book division. As soon as a new supplement or edition is published (usually annually) for a title you’ve previously purchased and requested to be placed on standing order, we’ll ship it to you to review for 30 days without any obligation. During this period, you can either (a) honor the invoice and receive a 5% discount (in addition to any other discounts you may qualify for) off the then-current price of the update, plus shipping and handling or (b) return the book(s), in which case, your invoice will be cancelled upon receipt of the book(s). Call us for a prepaid UPS label for your return. It’s as simple and easy as that. Most importantly, standing orders mean you will never have to worry about the timeliness of the information you’re relying on. And, you may discontinue standing orders at any time by contacting us at 1.800.960.1220 or by sending an email to firstname.lastname@example.org.
Put me on standing order at a 5% discount off list price of all future updates, in addition to any other discounts I may quality for. (Returnable within 30 days.)
Notify me when updates are available (No standing order will be created).
This Bloomberg BNA report is available on standing order, which ensures you will all receive the latest edition. This report is updated annually and we will send you the latest edition once it has been published. By signing up for standing order you will never have to worry about the timeliness of the information you need. And, you may discontinue standing orders at any time by contacting us at 1.800.372.1033, option 5, or by sending us an email to email@example.com.
Put me on standing order
Notify me when new releases are available (no standing order will be created)