On July 31, 2018, the Division of Corporation Finance issued two Compliance and Disclosure Interpretations (CDIs) addressing Notices of Exempt Solicitation in connection with Exchange Act Rule 14a-6(g)(1). The CDIs stated that a soliciting party that is not subject to Exchange Act Rule 14a-6(g)(1) may voluntarily submit a Notice of Exempt Solicitation provided that it is submitted under a cover which presents all of the information required by Exchange Act Rule 14a-103 before any written soliciting materials. Such cover must clearly state the submission was made on a voluntary basis, allowing investors to see that the soliciting party is not required to provide the Notice of Exempt Solicitation as a beneficial owner of more than $5 million of the class of subject securities. For more information see https://www.sec.gov/corpfin/proxy-rules-schedules-14a-14c-cdi#126
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