November / December 2025

• The SEC’s exit from no-action relief on Rule 14a-8 gives companies more discretion, but increases risk

• New White House directives are also injecting uncertainty into the 2026 proxy season (and beyond)

• Despite a quiet November, significant behind-the-scenes planning signals a busy year for hedge fund activism

• Recent developments—from paused California climate rules to evolving European standards and pressure on BlackRock—exemplify continued regulatory flux within the governance landscape