Topic
No-Action Letters
36 published works
The CLS Blue Sky Blog
SEC Commissioner Speaks Out Against Announcement on No-Action Requests
By Announcement today [November 17], the Division of Corporation Finance has apparently determined that, as a matter of “resource and timing considerations,” it will not respond to no-action requests for…
Free Writings + Perspectives
Division of Corporation Finance Issues No Action Letter to DoubleZero Foundation
By Liz Walsh
On September 29, 2025, the Chief Counsel’s Office of the U.S. Securities and Exchange Commission’s (the “Commission”) Division of Corporation Finance issued a no action letter to the DoubleZero Foundation…
The CLS Blue Sky Blog
Skadden Discusses SEC Grant of No-Action Relief for Retail Voting Program
By Brian V. Breheny, Raquel Fox, Marc S. Gerber, Elizabeth R. Gonzalez-Sussman andJoshua Shainess
On September 15, 2025, the Staff of the U.S. Securities and Exchange Commission’s (SEC’s) Office of Mergers & Acquisition issued a no-action letter to Exxon Mobil Corporation that allows for the adoption…
Consumer Financial Services Review
New Action on No-Action Letters – CFPB Begins Accepting Applications Under Updated No-Action Letter Procedures
By Holly Spencer Bunting, Kelly Truesdale
The US Consumer Financial Protection Bureau is giving no-action letters a second chance. On January 8, 2025, the CFPB issued a policy statement setting forth new procedures for companies to request supervisory…
Consumer Finance Monitor
CFPB re-establishes regulatory sandbox, no-action letter programs
By Richard J. Andreano, Jr., Ronald K. Vaske, John L. Culhane, Jr.
In an effort to foster innovation in financial services, the CFPB is reinstituting its programs that allow companies to obtain regulatory safe harbors through no-action letters and sandboxes to test…
Public Chatter
Shareholder Proposals: Corp Fin Changes Incoming No-Action Request Process
Starting this week, Corp Fin has changed how it will accept no-action requests regarding exclusion of shareholder proposals under Rule 14a-8. As reflected on Corp Fin’s Shareholder Proposals no-action responses…
Global Investigations & Compliance Review
FinCEN Requests Public Comments on Potential No-Action Letter Process
Thanks to our Summer Associate, Apollo Yong, for his work on this timely blog. On June 6, 2022, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department…
Consumer FinSights
FinCEN Proposes No-Action Letter Process
By Jeffrey Chapman, Alexander Madrid
On June 3, 2022, the Financial Crimes Enforcement Network (FinCen) issued an Advance Notice of Proposed Rulemaking proposing public comment on the enactment of a no-action letter process. This Advanced…
Money Laundering Watch
FinCEN Seeks Public Comments on No-Action Letters
On June 3, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued an Advance Notice of Proposed Rulemaking (“ANPRM”) that seeks public comment on the implementation of a “no-action letter” process…
Corporate and Securities Law
SEC to Again Respond to Rule 14a-8 No-Action Requests