On September 13, 2018, the SEC withdrew two no-action letters issued in 2004 to two proxy advisory firms. Some folks (like me!) are hopeful that the withdrawal of these no-action letters is a first step (albeit a small step) towards proxy advisory firm reform. If you would like to learn more about this topic, please see our Firm's client alert entitled "Proxy Advisory Firm Guidance Withdrawn by the SEC," which our Firm published this morning.
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