A January 23, 2026, guidance from the staff of the U.S. Securities and Exchange Commission (Question 126.06), has reshaped how shareholders can communicate during proxy season. ICCR and As You Sow have stepped up to partially fill the void, but instead of having this information pushed out to them, shareholders must now go looking for […]
In Question 126.06, of an interpretative bulletin issued on January 23, 2026, the SEC’s Division of Corporation Finance clarified that only shareholders who beneficially own more than $5 million of a class of securities may file Notices of Exempt Solicitation under Exchange Act Rule 14a-6(g)(1). While the SEC staff has for decades permitted all shareholders to voluntarily […]