Which of the Following Statements About an SEC No-Action Letter

Which of the following statements about an SEC no-action letter is false?

A) No-action letters state the SEC will not take legal action against the issuer if the issuer acts as indicated in the no-action letter.
B) No-action letters are binding on the SEC commissioners.
C) Issuers that comply with the no-action letters rarely face SEC action.
D) Issuers often seek no-action letters before making exempted offerings of securities and excluding shareholder proposals from their proxy statements.