ExxonMobil receives the first no-action letter
SEC staff addresses Rules 14a-4(d)(2) and (3), establishing the first public-company path for board-aligned standing instructions.
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DEVELOPMENT RECORD
How we
How we
got here.
The regulatory actions, issuer launches, operating evidence and challenges that turned a one-company experiment into a reusable framework.
Investor advocates ask the SEC to reconsider
As You Sow and ICCR argue that the standing proxy conflicts with proxy-form and contemporaneous-delivery rules.
ExxonMobil expands enrollment communications
Filed materials add personalized outreach, web information, FAQs, video and social advertising.
Early adoption crosses 100,000 holders
ExxonMobil reports about 150 million participating shares—more than 3% outstanding.
BigBear.ai enters its first live meeting
The proxy describes implementation, overrides, reminders and future cancellation.
Independent-options proposal receives 23.5%
709.7 million ExxonMobil shares support adding voting choices not aligned with the board.
SEC investor committee considers fund use
A draft recommendation supports opt-in standing instructions with disclosure and easy exit in the fund context.
First-year operating lessons emerge
Broadridge convenes ExxonMobil and BigBear.ai representatives to discuss launch experience.
Goldman Sachs broadens the roadmap
Its request expands pre-proxy enrollment and communications under a wider set of proxy rules.
Tesla establishes a reusable issuer framework
The SEC position expressly becomes available to other issuers operating in the same manner and contemplates centralized Hubs.
Funds receive a parallel framework
The Division of Investment Management provides a distinct directed-voting path for registered funds and BDCs.