SEC staff revives former guidance on shareholder proposals raising social policy issues

On February 12, the SEC’s Division of Corporation Finance issued Staff Legal Bulletin No. 14M (SLB 14M) to update its guidance on the “economic relevance” and “ordinary business” exclusions in Exchange Act Rule 14a-8, which is the SEC’s shareholder proposal rule. The SEC staff will apply the guidance during the current proxy season in responding to company no-action requests seeking to exclude shareholder proposals under those provisions.