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Out with the new, in with the old: SEC’s staff bulletin on shareholder proposals

Image of people seated at a table during a meeting.
Photo: Bryan Steffy/Getty Images for The Creative Coalition

Many companies have already submitted requests seeking exclusion of proposals pursuant to Rule 14a-8.

The SEC’s Division of Corporation Finance just published Staff Legal Bulletin No. 14M (SLB 14M), rescinding Staff Legal Bulletin No. 14L (SLB 14L), which came into force in November 2021.

By rescinding SLB 14L, the SEC has now narrowed the ability of registered firms to exclude shareholder proposals with “broad societal