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Confirming SEC Filer Status for the Upcoming Year

In light of the recent market volatility, public companies should keep in mind the upcoming annual re-evaluation of their filer status, as a change may have ramifications for both the timing and content for the following...more

SEC Considers Modification of Foreign Private Issuer Criteria: May Result in Fewer Foreign Companies Qualifying as FPIs

On June 4, 2025, the SEC released a Concept Release seeking public comment on potential changes to the definition of foreign private issuer (“FPI”), which changes may have the effect of reducing the number of foreign...more

Springtime Reminders for Public Companies

Approaches to Giving Guidance during Economic Uncertainty - As companies issue guidance during this period of economic uncertainty, their earnings announcements are taking different approaches, including...more

Time to Get Ready for the 2025 Reporting Season

As companies prepare for the upcoming proxy and annual report season, the following lists some of the key items to consider...more

SEC Roasts Keurig for Claims Regarding Recycling of K-Cup Pods

On September 10, 2024, the SEC announced that it had charged Keurig Dr. Pepper for making incomplete, and therefore inaccurate, statements regarding the recyclability of its popular K-cup pods....more

2024: Updates and Reminders for Upcoming Quarterly Filings

Potential regulatory uncertainty in light of Supreme Court decisions. The recent Supreme Court term produced several landmark decisions affecting administrative agencies, including...more

SEC Staff Issues Guidance for Reporting Cybersecurity Incidents Under Item 1.05 Versus Item 8.01 of Form 8-K

On May 21, 2024, the Director of the SEC’s Division of Corporation Finance issued a statement providing guidance on the use of Item 1.05 of Form 8-K to disclose cybersecurity incidents....more

Hot Topics to Consider for 2024 D&O Questionnaires

In light of new disclosure rules as well as investor interest, companies may wish to modify their D&O Questionnaires for the 2024 proxy season to address certain hot topics...more

Fifth Circuit Panel Rejects Sec Request for Additional Time to Substantiate New Stock Repurchase Disclosure Rules

As readers may recall, on October 31, 2023 the Fifth Circuit Court of Appeals in Chamber of Commerce v. SEC ruled that the SEC acted arbitrarily and capriciously, in violation of the Administrative Procedure Act, when it...more

Major Changes to 13D-13G Reporting Adopted by SEC

On October 10, 2023, the SEC adopted final amendments to Section 13(d) reporting obligations, including: ..Significantly accelerating filing deadlines ..Extending the filing cut-off from 5:30 pm ET to 10 pm ET...more

Mark Your Calendar: 2023 Key Compliance Deadlines for SEC’s Final Compensation Clawback Rules

As discussed in our recent blog post, the SEC recently adopted final executive officer incentive compensation clawback rules (the “Clawback Rules”) pursuant to the requirements of the Dodd-Frank Act.  The Clawback Rules,...more

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