Atkins notes federal securities laws do not mandate paper or mail delivery for disclosures.
“It is worth recognizing that the federal securities laws generally do not prescribe paper or mail as the required method of delivery for regulatory disclosures or reports.”
Atkins notes the Commission has long recognized no response from staff is required on shareholder proposal notices.
“Although the staff “has for many years engaged in the informal practice of expressing its enforcement position” in response to notices submitted under Rule 14a-8(j), the Commission has also long recognized that “[n]o response or other action by the Commission or its staff is required in regard to such communications.””