Capital Markets & Securities Law Watch

On January 23, 2026, the Securities and Exchange Commission (SEC) published a new compliance and disclosure interpretation in Question 133.02 that provides public companies with greater flexibility to condense the broker searches in connection with their stockholder meetings. Under this new interpretation, registrants may conduct the broker search less than 20 business days before the record date for the meeting, so long as the company reasonably believes that proxy materials will be disseminated to beneficial owners on time and otherwise complies with Rule 14a-13 under the Securities Exchange Act of 1934 (Exchange Act).