In November 2025, the Staff of the Securities and Exchange Commission (SEC) announced that, for the 2026 proxy season, with one narrow exception, the Staff would not respond to, or express views on, company no-action requests to exclude shareholder proposals submitted under Rule 14a-8. As a result, companies receiving shareholder proposals for inclusion in their 2026 proxy statements often engaged in a different analysis and risk assessment than in prior years. Many commentators and practitioners currently speculate that the Staff will take a similar hands-off approach for the 2027 proxy season. Accordingly, company approaches and investor reactions in the 2026 proxy season — including litigation, threatened use of advance notice bylaws to propose annual meeting business, and voting results on nominating and governance committee chairs — provide important inputs as companies determine how to assess the shareholder proposals they receive for the next proxy season.