To our clients and friends:
On September 15, 2025, the SEC issued a no-action letter in response to Exxon Mobil Corporation’s request to implement a “retail shareholder voting program” whereby its retail shareholders would authorize the perpetual voting of their shares in favor of management’s recommendations. Our Legal Update, available here, describes the requirements for— and potential ramifications of— implementing a standing proxy program. Our Legal Update also offers tips for public holding companies interested in pursuing the use of standing proxies.
Luse Gorman, PC regularly advises companies regarding corporate governance, shareholder matters and SEC developments. If you have any questions related to this Legal Update, please contact the authors. To learn more about our firm and services, please visit our website.