On September 15, 2025, the Staff of the Division of Corporation Finance of the Securities and Exchange Commission said that it will not recommend enforcement action if Exxon Mobil Corporation implements its proposed Retail Voting Program. See the no-action letter available here. Exxon’s proposed program would allow its retail shareholders to set standing voting instructions to vote their shares in line with the recommendations of Exxon’s board of directors, without requiring a separate voting election at each annual or special shareholder meeting. The no-action letter emphasizes the following key features of Exxon’s proposed Retail Voting Program:The program would be voluntary and available to all retail investors at no cost, including any registered owner or beneficial owners holding shares in street name. Exxon would publicly disclose the Retail Voting Program under cover of Schedule 14A when it is initiated, as well as any material changes to the program.