The SEC has issued updated guidance on Rule 14a-13(a), offering companies more flexibility when preparing for shareholder meetings. While registrants have traditionally been required to conduct a broker search at least 20 business days before the record date, as of January 2026, the SEC staff will not object to shorter timelines, provided companies reasonably believe proxy materials will still be distributed on time.

This update reflects the efficiency of modern, electronic processing, which can significantly reduce turnaround times. That said, the core objective remains unchanged: ensuring brokers, banks, and other nominees receive sufficient materials to reach beneficial owners in a timely manner.

Companies should still plan carefully, particularly for special meetings where timing constraints may apply, and ensure the search is initiated early enough to meet distribution requirements.