Other
2021-2022 No-Action Responses Issued Under Exchange Act Rule 14a-8
Oct. 19, 2021
This page contains final materials relating to no-action requests processed by the Division of Corporation Finance beginning on or after October 1, 2021 during the 2021-2022 shareholder proposal season. Any correspondence regarding a request for reconsideration is presented below the citation to the original no-action materials.
Additional Archives
Materials relating to no-action responses issued under Exchange Act Rule 14a-8 are archived below. Pursuant to the Federal Information Security Management Act of 2002 and OMB Memorandum M-07-16, we have removed, to the maximum extent practicable, personally identifiable information from the materials.
2021-2022 Shareholder Proposal No-Action Responses Chart
Alphabetical Listing
A
- 3M Company, February 7, 2022
- Abbott Laboratories, February 2, 2022
- AbbVie Inc., March 11, 2022
- AbbVie Inc., February 24, 2022
- The AES Corporation, February 16, 2022
- Aim ImmunoTech Inc., June 27, 2022
- Air Products and Chemicals, Inc., November 15, 2021 (see chart)
- Air Transport Services Group, Inc., February 22, 2022
- The Allstate Corporation, February 8, 2022
- The Allstate Corporation, January 24, 2022
- Alphabet Inc., April 15, 2022
- Alphabet Inc., April 15, 2022
- Alphabet Inc., April 15, 2022
- Alphabet Inc., April 11, 2022
- Alphabet Inc., April 11, 2022
- Alphabet Inc., April 11, 2022
- Alphabet Inc., April 12, 2022
- Alphabet Inc., April 12, 2022
- Alphabet Inc., April 12, 2022
- Amazon.com, Inc., April 7, 2022
- Amazon.com, Inc., April 7, 2022
- Amazon.com, Inc., April 7, 2022
- Amazon.com, Inc., April 8, 2022
- Amazon.com, Inc., April 8, 2022
- Amazon.com, Inc., April 8, 2022
- Amazon.com, Inc., April 6, 2022
- Amazon.com, Inc., April 5, 2022
- Amazon.com, Inc., April 5, 2022
- Amazon.com, Inc., February 28, 2022
- Amazon.com, Inc., February 28, 2022
- Amazon.com, Inc., February 8, 2022
- American Express Company, March 11, 2022
- American Tower Corporation, February 8, 2022
- Anthem, Inc., March 21, 2022
- Apple, Inc., December 22, 2021
- Apple, Inc., December 21, 2021
- Apple, Inc., December 20, 2021
- Apple, Inc., December 20, 2021
- Apple, Inc., December 20, 2021
- Apple, Inc., November 23, 2021 (see chart)
- Arlington Asset Investment Corp., March 31, 2022
- AT&T Inc., March 10, 2022
- AT&T Inc., January 26, 2022
- AT&T Inc., January 24, 2022
- AutoNation, Inc., February 25, 2022
- AutoZone, Inc., October 12, 2021 (see chart)
- Avinger, Inc., August 23, 2022
B
- Badger Meter, Inc., February 23, 2022
- Bank of America Corporation, March 1, 2022
- Baxter International Inc., January 12, 2022
- The Bank of New York Mellon Corporation, January 24, 2022
- Best Buy Co., Inc., April 22, 2022
- Best Buy Co., Inc., March 23, 2022
- The Boeing Company, February 10, 2022
- BlackRock, Inc., April 4, 2022
- BlackRock, Inc., April 4, 2022
- BlackRock, Inc., May 2, 2022
- Brinker International, Inc., September 15, 2022
- Broadridge Financial Solutions, Inc., September 16, 2022
C
- Charles River Laboratories International, Inc., January 24, 2022
- Chemed Corporation, March 28, 2022
- Cheniere Energy, Inc., April 7, 2022
- Chubb Limited, March 26, 2022
- Chubb Limited, March 26, 2022
- Church & Dwight Co., Inc., February 28, 2022
- Cisco Systems, Inc., October 3, 2022
- Citigroup Inc., March 7, 2022
- Colgate-Palmolive Company, January 26, 2022
- The Coca-Cola Company, March 10, 2022
- The Coca-Cola Company, February 16, 2022
- Coca-Cola Consolidated, Inc., February 23, 2022
- Comcast Corporation, April 13, 2022
- Comcast Corporation, April 13, 2022
- Comcast Corporation, April 6, 2022
- CoStar Group, Inc., April 5, 2022
- Costco Wholesale Corporation, November 15, 2021 (see chart)
- Costco Wholesale Corporation, November 12, 2021 (see chart)
- CVS Health Corporation, March 18, 2022
- CVS Health Corporation, March 17, 2022
- CVS Health Corporation, March 15, 2022
D
- DaVita Inc., February 4, 2022
- Deere & Company, January 3, 2022
- Deere & Company, November 12, 2021 (see chart)
- DexCom, Inc., February 11, 2022
- Dollar Tree, Inc., May 2, 2022
- Dominion Energy, Inc., March 10, 2022
- Dominion Energy, Inc., February 22, 2022
- Dominion Energy, Inc., February 4, 2022
- Dow Inc., February 15, 2022
- Dow Inc., February 15, 2022
- DuPont de Nemours, Inc., February 7, 2022
E
- Eagle Bancorp, Inc., March 29, 2022
- Edison International, February 23, 2022
- Edwards Lifesciences, December 22, 2021
- Eli Lilly and Company, January 26, 2022
- Eli Lilly and Company, March 7, 2022
- Eli Lilly and Company, March 8, 2022
- Eli Lilly and Company, March 9, 2022
- Etsy, Inc., March 2, 2022
- Etsy, Inc., February 7, 2022
- Etsy, Inc., April 19, 2022
- Exact Sciences Corporation, April 22, 2022
- Exxon Mobil Corporation, March 22, 2022
- Exxon Mobil Corporation, March 15, 2022
- Exxon Mobil Corporation, February 10, 2022
- Expeditors International of Washington, Inc., March 22, 2022
F
- Fortive Corporation, April 11, 2022
- Fox Corporation, September 6, 2022
G
- GameStop Corp., April 21, 2022
- GameStop Corp., April 21, 2022
- GameStop Corp., April 21, 2022
- General Electric Company, March 14, 2022
- General Electric Company, January 6, 2022
- General Motors Company, April 18, 2022
- The GEO Group, Inc., April 7, 2022
- Gilead Sciences, Inc., March 14, 2022
- The Goldman Sachs Group, Inc., March 8, 2022
- The Goldman Sachs Group, Inc., March 21, 2022
- The Goldman Sachs Group, Inc., January 4, 2022
- The Goodyear Tire & Rubber Company, March 7, 2022
H
- The Hartford Financial Services Group, Inc., March 28, 2022
- The Hershey Company, March 28, 2022
I
- IDACORP, Inc., April 1, 2022
- Intel Corporation, March 18, 2022
- Intel Corporation, March 16, 2022
- Intercontinental Exchange, Inc., March 15, 2022
- International Business Machines Corporation, December 29, 2021
- International Business Machines Corporation, February 8, 2022
- IQVIA Holdings Inc., January 12, 2022
- IQVIA Holdings Inc., January 20, 2022
J
- J.B. Hunt Transport Services, Inc., January 26, 2022
- Johnson & Johnson, March 4, 2022
- Johnson & Johnson, March 3, 2022
- Johnson & Johnson, March 2, 2022
- Johnson & Johnson, February 7, 2022
- Johnson & Johnson, February 8, 2022
- Johnson & Johnson, February 9, 2022
- Johnson & Johnson, February 11, 2022
- JPMorgan Chase & Co., March 17, 2022
- JPMorgan Chase & Co., January 28, 2022
- JPMorgan Chase & Co., March 25, 2022
- JPMorgan Chase & Co., March 25, 2022
- JPMorgan Chase & Co., March 25, 2022
- JPMorgan Chase & Co., March 25, 2022
- JPMorgan Chase & Co., April 19, 2022
- JPMorgan Chase & Co., March 25, 2022
K
- KeyCorp, February 8, 2022
- Kinder Morgan, Inc., February 14, 2022
- The Kraft Heinz Company, January 26, 2022
- The Kraft Heinz Company, February 14, 2022
- The Kroger Co., April 14, 2022
L
- Laboratory Corporation of America Holdings, March 3, 2022
- Lantheus Holdings, Inc., March 11, 2022
- Legacy Housing Corporation, October 5, 2022
- Levi Strauss & Co., February 8, 2022
- Levi Strauss & Co., February 10, 2022
- Lowe’s Companies, Inc., April 7, 2022
- Lowe’s Companies, Inc., April 7, 2022
M
- MasterCard Incorporated, April 22, 2022
- McDonald’s Corporation, April 5, 2022
- Merck & Co., Inc., February 15, 2022
- Meta Platforms, Inc., April 2, 2022
- Meta Platforms, Inc., March 31, 2022
- Meta Platforms, Inc., April 2, 2022
- Meta Platforms, Inc., April 2, 2022
- Meta Platforms, Inc., March 30, 2022
- Meta Platforms, Inc., April 2, 2022
- Meta Platforms, Inc., March 17, 2022
- Microsoft Corporation, October 7, 2022
- Moderna, Inc. February 17, 2022
- Moderna, Inc, February 8, 2022
- Moody 's Corporation, January 26, 2022
- Morgan Stanley, March 25, 2022
N
- NextEra Energy, Inc., March 3, 2022
- NextEra Energy, Inc., January 12, 2022
- NextEra Energy, Inc., March 3, 2022
- Northrop Grumman Corporation, February 16, 2022
O
- Occidental Petroleum Corporation, March 15, 2022
- OGE Energy Corp., March 22, 2022
P
- PayPal Holdings, Inc., April 7, 2022
- PepsiCo, Inc., March 14, 2022
- PepsiCo, Inc., March 12, 2022
- PepsiCo, Inc., February 8, 2022
- Pfizer Inc., March 8, 2022
- Pfizer Inc., February 24, 2022
- Pfizer Inc., February 23, 2022
- Pfizer Inc., February 22, 2022
- Pfizer Inc., February 22, 2022
- Pfizer Inc., February 11, 2022
- Pfizer Inc., February 10, 2022
- Pfizer Inc., January 20, 2022
- Post Holdings, Inc., November 4, 2021 (see chart)
- PPG Industries, Inc, March 1, 2022
- PPL Corporation, March 9, 2022
- The Procter & Gamble Company, July 18, 2022
- The Procter & Gamble Company, August 19, 2022
Q
- Qumu Corporation, April 5, 2022
- Quotient Technology Inc., May 6, 2022
R
- Reliance Steel & Aluminum Co., January 19, 2022
- Redfin Corporation, April 22, 2022
- Repligen Corporation, April 1, 2022
- Rite Aid Corporation, May 2, 2022
- Rite Aid Corporation, May 3, 2022
- Ruth’s Hospitality Group, Inc., April 8, 2022
S
- salesforce.com, inc., March 10, 2022
- Sempra Energy, March 15, 2022
- Snowflake Inc., March 22, 2022
- South Jersey Industries, Inc., January 18, 2022
- Southwestern Energy Company, March 15, 2022
- S&P Global Inc., February 1, 2022
- Starbucks Corporation, January 19, 2022
- Starbucks Corporation, November 23, 2021 (see chart)
- State Street Corporation, April 1, 2022
- STERIS plc, May 23, 2022
- Stryker Corporation, February 7, 2022
T
- Target Corporation, March 2, 2022
- Target Corporation, February 22, 2022
- Target Corporation, February 15, 2022
- Teladoc Health, Inc., January 31, 2022
- Tesla, Inc., May 6, 2022
- Texas Instruments Incorporated, February 18, 2022
- Texas Pacific Land Corporation, September 26, 2022
- Texas Pacific Land Corporation, September 26, 2022
- Texas Pacific Land Corporation, September 26, 2022
- Texas Pacific Land Corporation, September 26, 2022
- Texas Pacific Land Corporation, December 22, 2021
- Texas Pacific Land Corporation, November 23, 2021 (see chart)
- Texas Pacific Land Corporation, November 23, 2021 (see chart)
- Texas Pacific Land Corporation, November 23, 2021 (see chart)
- The TJX Companies, Inc., April 15, 2022
- The TJX Companies, Inc., April 15, 2022
- Tractor Supply Company, March 9, 2022
- The Travelers Companies. Inc., March 30, 2022
- The Travelers Companies. Inc., April 1, 2022
- The Travelers Companies. Inc., March 30, 2022
- The Travelers Companies. Inc., March 31, 2022
V
- Verizon Communications Inc., March 17, 2022
- Verizon Communications Inc., March 17, 2022
- Verizon Communications Inc., February 24, 2022
- Verizon Communications Inc., January 14, 2022
- Visa Inc., November 8, 2022
W
- Walgreens Boots Alliance, Inc., November 8, 2022
- Walgreens Boots Alliance, Inc., November 8, 2022
- Walgreens Boots Alliance, Inc., October 12, 2021 (see chart)
- Walgreens Boots Alliance, Inc., October 26, 2021 (see chart)
- Walmart Inc., April 12, 2022
- The Walt Disney Company, January 19, 2022
- The Walt Disney Company, January 19, 2022
- The Walt Disney Company, January 19, 2022
- The Walt Disney Company, January 19, 2022
- The Walt Disney Company, January 12, 2022
- The Walt Disney Company, January 6, 2022
- Wells Fargo & Company, February 28, 2022
- The Wendy’s Company, March 16, 2022
- The Western Union Company, March 3, 2022
XYZ
- Xerox Holdings Corporation, February 9, 2022
- Xylem Inc., January 26, 2022
- Yelp Inc., March 25, 2022
- Yum! Brands, February 4, 2022
- Zoetis Inc., March 30, 2022
- Zynga Inc., June 6, 2022
- Zynga Inc., February 1, 2022
Chronological Listing
November 2022
- Visa Inc., November 8, 2022
- Walgreens Boots Alliance, Inc., November 8, 2022
- Walgreens Boots Alliance, Inc., November 8, 2022
October 2022
- Microsoft Corporation, October 7, 2022
- Legacy Housing Corporation, October 5, 2022
- Cisco Systems, Inc., October 3, 2022
September 2022
- Texas Pacific Land Corporation, September 26, 2022
- Texas Pacific Land Corporation, September 26, 2022
- Texas Pacific Land Corporation, September 26, 2022
- Texas Pacific Land Corporation, September 26, 2022
- Broadridge Financial Solutions, Inc., September 16, 2022
- Brinker International, Inc., September 15, 2022
- Fox Corporation, September 6, 2022
August 2022
- Avinger, Inc., August 23, 2022
- The Procter & Gamble Company, August 19, 2022
July 2022
- The Procter & Gamble Company, July 18, 2022
June 2022
- Aim ImmunoTech Inc., June 27, 2022
- Zynga Inc., June 6, 2022
May 2022
- STERIS plc, May 23, 2022
- Tesla, Inc., May 6, 2022
- Quotient Technology Inc., May 6, 2022
- Rite Aid Corporation, May 3, 2022
- Rite Aid Corporation, May 2, 2022
- Dollar Tree, Inc., May 2, 2022
- BlackRock, Inc., May 2, 2022
April 2022
- Exact Sciences Corporation, April 22, 2022
- MasterCard Incorporated, April 22, 2022
- Best Buy Co., Inc., April 22, 2022
- Redfin Corporation, April 22, 2022
- GameStop Corp., April 21, 2022
- GameStop Corp., April 21, 2022
- GameStop Corp., April 21, 2022
- JPMorgan Chase & Co., April 19, 2022
- Etsy, Inc., April 19, 2022
- General Motors Company, April 18, 2022
- Alphabet Inc., April 15, 2022
- Alphabet Inc., April 15, 2022
- Alphabet Inc., April 15, 2022
- The TJX Companies, Inc., April 15, 2022
- The TJX Companies, Inc., April 15, 2022
- The Kroger Co., April 14, 2022
- Comcast Corporation, April 13, 2022
- Comcast Corporation, April 13, 2022
- Alphabet Inc., April 12, 2022
- Alphabet Inc., April 12, 2022
- Alphabet Inc., April 12, 2022
- Walmart Inc., April 12, 2022
- Fortive Corporation, April 11, 2022
- Alphabet Inc., April 11, 2022
- Alphabet Inc., April 11, 2022
- Alphabet Inc., April 11, 2022
- Ruth’s Hospitality Group, Inc., April 8, 2022
- Amazon.com, Inc., April 8, 2022
- Amazon.com, Inc., April 8, 2022
- Amazon.com, Inc., April 8, 2022
- PayPal Holdings, Inc., April 7, 2022
- Amazon.com, Inc., April 7, 2022
- Amazon.com, Inc., April 7, 2022
- Amazon.com, Inc., April 7, 2022
- Cheniere Energy, Inc., April 7, 2022
- The GEO Group, Inc., April 7, 2022
- Lowe’s Companies, Inc., April 7, 2022
- Lowe’s Companies, Inc., April 7, 2022
- Comcast Corporation, April 6, 2022
- Amazon.com, Inc., April 6, 2022
- Qumu Corporation, April 5, 2022
- CoStar Group, Inc., April 5, 2022
- McDonald’s Corporation, April 5, 2022
- Amazon.com, Inc., April 5, 2022
- Amazon.com, Inc., April 5, 2022
- BlackRock, Inc., April 4, 2022
- BlackRock, Inc., April 4, 2022
- Meta Platforms, Inc., April 2, 2022
- Meta Platforms, Inc., April 2, 2022
- Meta Platforms, Inc., April 2, 2022
- Meta Platforms, Inc., April 2, 2022
- The Travelers Companies. Inc., April 1, 2022
- IDACORP, Inc., April 1, 2022
- Repligen Corporation, April 1, 2022
- State Street Corporation, April 1, 2022
March 2022
- The Travelers Companies. Inc., March 31, 2022
- Meta Platforms, Inc., March 31, 2022
- Arlington Asset Investment Corp., March 31, 2022
- Zoetis Inc., March 30, 2022
- The Travelers Companies. Inc., March 30, 2022
- The Travelers Companies. Inc., March 30, 2022
- Meta Platforms, Inc., March 30, 2022
- Eagle Bancorp, Inc., March 29, 2022
- Chemed Corporation, March 28, 2022
- The Hartford Financial Services Group, Inc., March 28, 2022
- The Hershey Company, March 28, 2022
- Chubb Limited, March 26, 2022
- Chubb Limited, March 26, 2022
- Yelp Inc., March 25, 2022
- Morgan Stanley, March 25, 2022
- JPMorgan Chase & Co., March 25, 2022
- JPMorgan Chase & Co., March 25, 2022
- JPMorgan Chase & Co., March 25, 2022
- JPMorgan Chase & Co., March 25, 2022
- JPMorgan Chase & Co., March 25, 2022
- Best Buy Co., Inc., March 23, 2022
- Snowflake Inc., March 22, 2022
- OGE Energy Corp., March 22, 2022
- Exxon Mobil Corporation, March 22, 2022
- Expeditors International of Washington, Inc., March 22, 2022
- The Goldman Sachs Group, Inc., March 21, 2022
- Anthem, Inc., March 21, 2022
- Intel Corporation, March 18, 2022
- CVS Health Corporation, March 18, 2022
- Verizon Communications Inc., March 17, 2022
- Verizon Communications Inc., March 17, 2022
- Meta Platforms, Inc., March 17, 2022
- JPMorgan Chase & Co., March 17, 2022
- CVS Health Corporation, March 17, 2022
- The Wendy’s Company, March 16, 2022
- Intel Corporation, March 16, 2022
- Southwestern Energy Company, March 15, 2022
- Sempra Energy, March 15, 2022
- Occidental Petroleum Corporation, March 15, 2022
- Exxon Mobil Corporation, March 15, 2022
- CVS Health Corporation, March 15, 2022
- Intercontinental Exchange, Inc., March 15, 2022
- General Electric Company, March 14, 2022
- Gilead Sciences, Inc., March 14, 2022
- PepsiCo, Inc., March 14, 2022
- PepsiCo, Inc., March 12, 2022
- Lantheus Holdings, Inc., March 11, 2022
- American Express Company, March 11, 2022
- AbbVie Inc., March 11, 2022
- salesforce.com, inc., March 10, 2022
- AT&T Inc., March 10, 2022
- The Coca-Cola Company, March 10, 2022
- Dominion Energy, Inc., March 10, 2022
- PPL Corporation, March 9, 2022
- Tractor Supply Company, March 9, 2022
- Eli Lilly and Company, March 9, 2022
- The Goldman Sachs Group, Inc., March 8, 2022
- Pfizer Inc., March 8, 2022
- Eli Lilly and Company, March 8, 2022
- Citigroup Inc., March 7, 2022
- Eli Lilly and Company, March 7, 2022
- The Goodyear Tire & Rubber Company, March 7, 2022
- Johnson & Johnson, March 4, 2022
- NextEra Energy, Inc., March 4, 2022
- Johnson & Johnson, March 3, 2022
- The Western Union Company, March 3, 2022
- Laboratory Corporation of America Holdings, March 3, 2022
- Target Corporation, March 2, 2022
- Johnson & Johnson, March 2, 2022
- Etsy, Inc., March 2, 2022
- PPG Industries, Inc, March 1, 2022
- Bank of America Corporation, March 1, 2022
February 2022
- Wells Fargo & Company, February 28, 2022
- Church & Dwight Co., Inc., February 28, 2022
- Amazon.com, Inc., February 28, 2022
- Amazon.com, Inc., February 28, 2022
- AutoNation, Inc., February 25, 2022
- Verizon Communications Inc., February 24, 2022
- Pfizer Inc., February 24, 2022
- AbbVie Inc., February 24, 2022
- Pfizer Inc., February 23, 2022
- Badger Meter, Inc., February 23, 2022
- Coca-Cola Consolidated, Inc., February 23, 2022
- Edison International, February 23, 2022
- Target Corporation, February 22, 2022
- Pfizer Inc., February 22, 2022
- Pfizer Inc., February 22, 2022
- Dominion Energy, Inc., February 22, 2022
- Air Transport Services Group, Inc., February 22, 2022
- Texas Instruments Incorporated, February 18, 2022
- Moderna, Inc. February 17, 2022
- Northrop Grumman Corporation, February 16, 2022
- The Coca-Cola Company, February 16, 2022
- The AES Corporation, February 16, 2022
- Target Corporation, February 15, 2022
- Merck & Co., Inc., February 15, 2022
- Dow Inc., February 15, 2022
- Dow Inc., February 15, 2022
- The Kraft Heinz Company, February 14, 2022
- Kinder Morgan, Inc., February 14, 2022
- Pfizer Inc., February 11, 2022
- Johnson & Johnson, February 11, 2022
- DexCom, Inc., February 11, 2022
- Pfizer Inc., February 10, 2022
- Levi Strauss & Co., February 10, 2022
- Exxon Mobil Corporation, February 10, 2022
- The Boeing Company, February 10, 2022
- Xerox Holdings Corporation, February 9, 2022
- Johnson & Johnson, February 9, 2022
- PepsiCo, Inc., February 8, 2022
- Moderna, Inc, February 8, 2022
- Levi Strauss & Co., February 8, 2022
- Amazon.com, Inc., February 8, 2022
- The Allstate Corporation, February 8, 2022
- KeyCorp, February 8, 2022
- Johnson & Johnson, February 8, 2022
- American Tower Corporation, February 8, 2022
- International Business Machines Corporation, February 8, 2022
- Stryker Corporation, February 7, 2022
- Johnson & Johnson, February 7, 2022
- DuPont de Nemours, Inc., February 7, 2022
- 3M Company, February 7, 2022
- Etsy, Inc., February 7, 2022
- DaVita Inc., February 4, 2022
- Dominion Energy, Inc., February 4, 2022
- Yum! Brands, February 4, 2022
- Abbott Laboratories, February 2, 2022
- S&P Global Inc., February 1, 2022
- Zynga Inc., February 1, 2022
January 2022
- Teladoc Health, Inc., January 31, 2022
- JPMorgan Chase & Co., January 28, 2022
- Colgate-Palmolive Company, January 26, 2022
- Xylem Inc., January 26, 2022
- The Kraft Heinz Company, January 26, 2022
- Eli Lilly and Company, January 26, 2022
- J.B. Hunt Transport Services, Inc., January 26, 2022
- AT&T Inc., January 26, 2022
- Moody 's Corporation, January 26, 2022
- Charles River Laboratories International, Inc., January 24, 2022
- AT&T Inc., January 24, 2022
- The Allstate Corporation, January 24, 2022
- The Bank of New York Mellon Corporation, January 24, 2022
- Pfizer Inc., January 20, 2022
- IQVIA Holdings Inc., January 20, 2022
- Reliance Steel & Aluminum Co., January 19, 2022
- The Walt Disney Company, January 19, 2022
- The Walt Disney Company, January 19, 2022
- The Walt Disney Company, January 19, 2022
- The Walt Disney Company, January 19, 2022
- Starbucks Corporation, January 19, 2022
- South Jersey Industries, Inc., January 18, 2022
- Verizon Communications Inc., January 14, 2022
- The Walt Disney Company, January 12, 2022
- NextEra Energy, Inc., January 12, 2022
- IQVIA Holdings Inc., January 12, 2022
- Baxter International Inc., January 12, 2022
- The Walt Disney Company, January 6, 2022
- General Electric Company, January 6, 2022
- The Goldman Sachs Group, Inc., January 4, 2022
- Deere & Company, January 3, 2022
December 2021
- International Business Machines Corporation, December 29, 2021
- Apple, Inc., December 22, 2021
- Edwards Lifesciences, December 22, 2021
- Texas Pacific Land Corporation, December 22, 2021
- Apple, Inc., December 21, 2021
- Apple, Inc., December 20, 2021
- Apple, Inc., December 20, 2021
- Apple, Inc., December 20, 2021
November 2021
- Apple, Inc., November 23, 2021 (see chart)
- Starbucks Corporation, November 23, 2021 (see chart)
- Texas Pacific Land Corporation, November 23, 2021 (see chart)
- Texas Pacific Land Corporation, November 23, 2021 (see chart)
- Texas Pacific Land Corporation, November 23, 2021 (see chart)
- Costco Wholesale Corporation. November 15, 2021 (see chart)
- Air Products and Chemicals, Inc., November 15, 2021 (see chart)
- Deere & Company, November 12, 2021 (see chart)
- Costco Wholesale Corporation. November 12, 2021 (see chart)
- Post Holdings, Inc., November 4, 2021 (see chart)
October 2021
- Walgreens Boots Alliance, Inc., October 26, 2021 (see chart)
- AutoZone, Inc., October 12, 2021 (see chart)
- Walgreens Boots Alliance, Inc., October 12, 2021 (see chart)
Chart of No-Action Responses From October 1, 2021 to November 30, 2021
The staff's responses to Rule 14a-8 no-action requests issued between October 1, 2021 and November 30, 2021 are disclosed in the following chart. The column titled "Date of company's initial submission" contains a hyperlink to the company's initial submission to the staff, and the column titled "Date of staff's response" contains a hyperlink to the correspondence relating to the staff's response, including any letter issued by the staff, the company's initial submission and any subsequent correspondence, in reverse chronological order. On December 13, 2021, the Division announced that the staff would return to the practice of responding to each shareholder proposal no-action request with a written letter and would no longer communicate responses via a chart. Accordingly, the staff’s responses will no longer be communicated via this chart.
Company that submitted the reasons for excluding the proposal. | Shareholder that submitted the proposal to the company. | Date of company's initial submission. | Regulatory bases asserted by company to exclude the proposal. | Staff's response to the company's request. | Date of staff's response. | Did the staff respond by letter? |
---|---|---|---|---|---|---|
Texas Pacific Land Corporation | Robert Zaccheo, Jr. | 9/23/2021 | (reconsid.) Rule 14a-8(i)(7) |
Request for reconsideration granted Concur that Rule 14a-8(i)(7) provides a basis to exclude (ordinary business) |
11/23/2021 | No |
Texas Pacific Land Corporation | Gabriel Gliksberg | 11/1/2021 | Rule 14a-8(e)(2) Rule 14a-8(i)(2) Rule 14a-8(i)(6) Rule 14a-8(i)(8) |
Unless revised as specified, concur that rule 14a-8(i)(8) provides a basis to exclude Unable to concur with exclusion on any of the other bases asserted |
11/23/2021 | Yes |
Texas Pacific Land Corporation | Special Opportunities Fund, Inc. | 11/9/2021 | Rule 14a-8(c) Rule 14a-8(e)(2) Rule 14a-8(i)(3) Rule 14a-8(i)(7) |
Concur that Rule 14a-8(c) provides a basis to exclude | 11/23/2021 | No |
Apple Inc. | Green Century Balanced Fund | 10/18/2021 | Rule 14a-8(i)(7) | Withdrawn | 11/23/2021 | No |
Starbucks Corporation | James McRitchie | 11/9/2021 | Rule 14a-8(e)(2) Rule 14a-8(i)(3) |
Withdrawn | 11/23/2021 | No |
Costco Wholesale Corporation | American Baptist Home Mission Society et al. | 9/21/2021 | Rule 14a-8(i)(10) | Unable to concur that Rule 14a-8(i)(10) provides a basis to exclude | 11/15/2021 | No |
Air Products and Chemicals, Inc. | The Nathan Cummings Foundation | 9/24/2021 | Rule 14a-8(i)(7) Rule 14a-8(i)(10) |
Unable to concur with exclusion on any of the bases asserted | 11/15/2021 | No |
Deere & Company | Green Century Balanced Fund | 10/15/2021 | Rule 14a-8(i)(7) Rule 14a-8(i)(10) |
Withdrawn | 11/12/2021 | No |
Costco Wholesale Corporation |
Green Century Balanced Fund | 9/21/2021 | Rule 14a-8(i)(7) | Withdrawn | 11/12/2021 | No |
Post Holdings, Inc. | Franciscan Sisters of Perpetual Adoration | 9/17/2021 | Rule 14a-8(i)(7) Rule 14a-8(i)(10) |
Withdrawn | 11/04/2021 | No |
Walgreens Boots Alliance, Inc. | Myra K. Young | 9/20/2021 | Rule 14a-8(i)(6) Rule 14a-8(i)(7) |
Withdrawn | 10/26/2021 | No |
Walgreens Boots Alliance, Inc. | Kenneth Steiner | 9/10/2021 | Rule 14a-8(e)(2) | Concur that Rule 14a-8(e)(2) provides a basis to exclude | 10/12/2021 | No |
AutoZone, Inc. | Elizabeth Gale Michaels Rev Tr | 8/6/2021 | Rule 14a-8(i)(7) Rule 14a-8(i)(10) |
Unable to concur with exclusion on any of the bases asserted | 10/12/2021 | No |