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A Guide to Redacting Commercially Sensitive Information From Exhibits Filed With the SEC

Rules requiring material agreements to be filed as exhibits to reports and registration statements with the Securities and Exchange Commission (SEC) were amended to permit the redaction of immaterial and commercially...more

SEC Proposes Changes to Financial Disclosure Requirements for Acquisitions and Dispositions

On May 3, 2019, the Securities and Exchange Commission (SEC) proposed extensive changes to the financial disclosure requirements for business acquisitions and dispositions. The proposed amendments are intended to reduce...more

NYSE Revises Exceptions to Shareholder Approval Rules

On March 20, 2019, the Securities and Exchange Commission (SEC) approved an amendment to the New York Stock Exchange (NYSE) requirement that listed companies obtain shareholder approval for certain share issuances. The...more

SEC Modernizes and Simplifies Disclosure and Compliance Requirements

On March 20, 2019, the Securities and Exchange Commission (SEC) adopted rule changes, as mandated by the Fixing America’s Surface Transportation Act (FAST Act), to modernize and simplify the disclosure and compliance...more

Reminders for Annual Meeting Proxy Materials

When finalizing proxy materials for annual shareholder meetings, companies should consider the following U.S. Securities and Exchange Commission (SEC) rules and related SEC staff guidance, as well as stock exchange listing...more

SEC Proposes New Rule 163B to Expand ‘Testing-the-Waters’ Communications to All Issuers

On February 19, 2019, the Securities and Exchange Commission (SEC) voted to propose a new rule and related amendments under the Securities Act that would expand the permissible use of testing-the-waters communications to...more

SEC Staff Issues Interpretive Guidance on Board Diversity Disclosures

On February 6, 2019, the Division of Corporation Finance (Staff) of the Securities and Exchange Commission published new interpretive guidance regarding board diversity disclosures, which should be considered when preparing...more

SEC Adopts Hedging Policy Disclosure Requirements

On December 18, 2018, the Securities and Exchange Commission (SEC) adopted final rules that will require hedging policy disclosures. The new rules, mandated by Section 955 of the Dodd-Frank Wall Street Reform and Consumer...more

SEC Requests Public Comment on Earnings Releases and Quarterly Reports

On December 18, 2018, the Securities and Exchange Commission (SEC) issued a concept release requesting comments on the nature, content and timing of earnings releases and quarterly reports made by reporting companies.1 In...more

SEC and EDGAR System to Be Closed December 5, 2018, for National Day of Mourning

On Wednesday, December 5, 2018, federal government departments and agencies, including the Securities and Exchange Commission (SEC), will be closed in observance of a national day of mourning for former President George H.W....more

SEC Staff Issues Shareholder Proposal Guidance

On October 23, 2018, the Division of Corporation Finance (Staff) of the U.S. Securities and Exchange Commission (SEC) published Staff Legal Bulletin No. 14J (SLB 14J), which provides important guidance concerning shareholder...more

SEC Investigative Report on Cybersecurity Emphasizes Internal Controls

On October 16, 2018, the Securities and Exchange Commission (SEC) issued a Report of Investigation (Report) detailing an investigation by the SEC’s Enforcement Division into the internal accounting controls of nine issuers...more

Reminders of Recent Updates for Upcoming SEC Filings

The SEC recently adopted amendments to disclosure requirements applicable to various registration statements and periodic reports, including minor changes to applicable form cover pages. ...more

SEC Modernizes Certain Disclosure Requirements

On August 17, 2018, the Securities and Exchange Commission (SEC) amended certain disclosure requirements that have become duplicative or outdated. The amendments, which reflect the SEC’s efforts to implement the Fixing...more

SEC Proposes to Ease Disclosures Required by Rules 3-10 and 3-16 of Regulation S-X in Certain Registered Debt Offerings

On July 24, 2018, the Securities and Exchange Commission (SEC) proposed rule amendments that would simplify the financial disclosure requirements applicable to registered debt offerings for guarantors and issuers of...more

The JOBS Act 3.0: Regulatory Reforms Pass House of Representatives

On July 17, 2018, the House of Representatives passed the JOBS and Investor Confidence Act (JOBS Act 3.0), a package of reforms consisting of 32 pieces of legislation principally designed to spur entrepreneurship by...more

SEC Eases Disclosure Threshold Under Rule 701

On July 18, 2018, the Securities and Exchange Commission (SEC) amended Rule 701(e) of the Securities Act of 1933 (Securities Act), as mandated by the Economic Growth, Regulatory Relief, and Consumer Protection Act. The...more

SEC’s Proposed Transaction Fee Pilot Program Continues to Provoke Discussion

On March 14, 2018, the Securities and Exchange Commission (SEC) proposed new Rule 610T of Regulation NMS, which would establish a pilot program to study the effects of potential changes considered by the SEC on certain...more

Capital Markets Alert – SEC Expands ‘Smaller Reporting Company’ Definition

On June 28, 2018, the Securities and Exchange Commission (SEC) approved amendments to the definition of “smaller reporting company” (SRC) that will substantially expand the number of companies that will qualify for the scaled...more

Recent Developments Regarding Admission of US Companies to Russian Stock Exchanges

In April 2018, the Moscow Exchange, reportedly the largest exchange in Russia, announced that it intends to admit securities of approximately 50 major U.S. and other foreign companies to public trading in the non-quotation...more

Conflict Minerals Disclosures Due May 31, 2018

As a reminder, conflict minerals disclosures on Forms SD are required to be filed with the Securities and Exchange Commission (SEC) no later than May 31, 2018....more

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