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SEC Proposes Amendments to MD&A

The Securities and Exchange Commission yesterday voted to propose amendments to the Regulation S-K requirements for Management’s Discussion and Analysis, or MD&A, and also issued agency guidance relating to MD&A. ...more

Omitting Discussion of Third Year in MD&A Sections

As discussed in earlier blog posts, as a result of various FAST Act mandated changes to Regulation S-K, which were adopted by the Securities and Exchange Commission and became effective in May 2019, a registrant may omit a...more

SEC Approves FINRA Rule 5110 Amendments

Recently, the Securities and Exchange Commission approved FINRA’s proposed amendments to its Corporate Financing Rule, which are intended to modernize, simplify, and streamline the rule....more

Chair Clayton Testifies in Congress

In his testimony in Congress, Securities and Exchange Commission Chair Jay Clayton provided an update on the rulemaking work undertaken by the SEC during the fiscal year and provided updates on the SEC’s priorities. ...more

SEC Small Entity Compliance Guide on Testing the Waters

The SEC’s amendment to the test-the-waters provisions, extending the ability to test-the-waters to issuers that are not emerging growth companies (“EGCs”), is now effective. The guide summarizes the provisions of new Rule...more

Testing the Waters for All – New Rule 163B Expands TTW to All Issuers: First Analysis

In this Lexis Practice Advisor Practice Note, we discuss new Rule 163B adopted by the US Securities and Exchange Commission (SEC). On September 26, 2019, the SEC extended the ability to test the waters to all issuers by...more

SEC’s Investor Advisory Committee Upcoming Meetings

On September 5, 2019, the Investor Advisory Committee will hold an open meeting (telephonic) in order to consider and address recommendations regarding the proxy process. On September 19, the Committee will hold an in-person...more

Final Rules to Allow Exchange Act Reporting Companies to Use Regulation A

The Securities and Exchange Commission adopted final rules yesterday making Regulation A available to reporting companies. The Commission was required to amend Regulation A pursuant to the mandate in the financial services...more

Legal Update: Will the Earnings Release Be the New 10-Q?

On December 18, 2018 the Commission published a Request for Comment on Earnings Releases and Quarterly Reports (the “Request”), which solicits public comment on both earnings releases and the frequency of periodic reporting....more

Unicorn Stock Options and Regulatory Reform

In a recent paper titled “Unicorn Stock Options – Golden Goose or Trojan Horse?” Anat Alon-Beck analyzes the issues arising in connection with stock-based compensation awarded to employees of unicorns given the trend toward...more

Insights Regarding Areas of Focus for Division of Corporation Finance

Speaking at a session at the American Bar Association’s annual meeting, a representative of the Securities and Exchange Commission’s Division of Corporation Finance (Michael Seaman) provided guidance for attendees regarding...more

Ending Quarterly Filings? Or Just Discontinuing Quarterly Guidance?

Even before the Trump tweet, discussions regarding interim reporting requirements for U.S. public companies had been ongoing for several years. ...more

Commission Responds to Tweet

As we previously blogged, a Trump tweet called on the Securities and Exchange Commission to undertake a study regarding the costs and benefits of quarterly versus semi-annual filings. ...more

Commission Adopts Amendments as Part of Disclosure Effectiveness Initiative

Last week, the Securities and Exchange Commission adopted amendments to certain disclosure requirements that have become duplicative, overlapping, or outdated. ...more

Will a Tweet End 10-Qs?

In a very early morning tweet, the President chose to comment on the requirement to file quarterly reports on Form 10-Q. ...more

Upcoming SEC Open Meeting on Rule 701 and Regulation S-X proposals

The Securities and Exchange Commission will hold an open meeting on July 18th in order to consider the changes to Rule 701 required by the Crapo Act about which we previously blogged (see: https://goo.gl/3BNfb5), as well as...more

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