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SEC’s Fall 2023 Reg-Flex Agenda is out—climate disclosure rules delayed again

The SEC’s Fall 2023 Reg-Flex Agenda—according to the preamble, compiled as of August 22, 2023, reflecting “only the priorities of the Chair”—has now been posted. And it’s Groundhog Day again. All of the Corp Fin agenda items...more

Chamber files motion to vacate SEC’s final share repurchase rule

On October 31, the Fifth Circuit issued an opinion in Chamber of Commerce of the USA v. SEC, granting the Chamber’s petition for review of the SEC’s Share Repurchase Disclosure Modernization rule. The Court held that the “SEC...more

FASB issues final ASU requiring enhanced disclosure of segment expenses

The FASB has announced a final Accounting Standards Update designed to improve disclosures about public companies’ reportable segments, particularly disclosures about significant segment expenses—information that the FASB...more

SEC Chief Accountant has some thoughts about the statement of cash flows

The SEC’s Office of Chief Accountant appears to be taking a hard look these days at statements of cash flows. In “The Statement of Cash Flows: Improving the Quality of Cash Flow Information Provided to Investors,” SEC Chief...more

Future of SEC’s ALJs looks bleak—but the administrative state? Not so much

Last week, SCOTUS heard oral argument in Jarkesy v. SEC (BTW, pronounced Járkəzē, according to his counsel). As you may have heard, that case is about the constitutionality of the SEC’s administrative law judges. There were...more

SEC concedes unable to correct defects in buyback rule

On October 31, the Fifth Circuit issued an opinion in Chamber of Commerce of the USA v. SEC, granting the Chamber’s petition for review of the SEC’s Share Repurchase Disclosure Modernization rule. The Court held that the “SEC...more

What special issues should Comp Committees think about next year?

In this Viewpoint, Issues Facing Compensation Committees in 2024, comp consultant Pay Governance takes a look at how the current economic and geopolitical uncertainty, together with an “onslaught” of new SEC rules, may affect...more

District Court views “shadow trading” to be within the “misappropriation” standard of §10(b)

In August 2021, the SEC filed a complaint in the U.S. District Court charging Matthew Panuwat, a former employee of Medivation Inc., an oncology-focused biopharma, with insider trading in advance of Medivation’s announcement...more

Fifth Circuit denies SEC request for more time to cure defects in share repurchase rule

You might recall that, on Halloween, the Fifth Circuit issued an opinion in Chamber of Commerce of the USA v. SEC, granting the Chamber’s petition for review of the Share Repurchase Disclosure Modernization rule. The Court...more

SEC postpones effective date of share repurchase rule

Today, the SEC announced that it had issued an order postponing the effective date of the Share Repurchase Disclosure Modernization rule. As a result, the Rule is stayed pending further SEC action. Why? You might recall...more

Corp Fin releases more new CDIs on pay versus performance

Yesterday, Corp Fin released yet another group of new and revised CDIs, these relating to pay-versus-performance disclosure. (See this PubCo post.) Several of the new CDIs address issues regarding peer groups and some provide...more

More new CDIs from Corp Fin

On the heels of the release of new proxy-related CDIs on Friday come another set of new CDIs from Corp Fin, released yesterday. The new CDIs, summarized below, relate to Securities Act Rules 456 and 457 (regarding completing...more

Corp Fin issues new CDIs regarding the proxy rules

On Friday, Corp Fin released some new CDIs, summarized below, relating to the proxy rules. The CDIs can all be found under the caption Proxy Rules and Schedule 14A, and all are new with one exception for a newly revised CDI...more

SEC reports Enforcement stats for fiscal 2023 —with big contributions from whistleblowers

The SEC has announced its Enforcement stats for fiscal 2023, which revealed that the SEC filed 784 total enforcement actions, up 3% from the 760 filed in fiscal 2022. However, the level of financial remedies declined in...more

SEC charges Charter Communications with controls violation related to 10b5-1 plans for company buybacks

Yesterday, the SEC announced a settled action against Charter Communications for “violating internal accounting controls requirements when it engaged in stock buybacks not authorized by its board of directors.” More...more

The PCAOB suggest some questions for audit committee members

The PCAOB has posted a 2023 audit committee resource that identifies a number of questions that audit committees may want “to consider amongst themselves or in discussions with their independent auditors, particularly given...more

Some highlights of the 2023 PLI Securities Regulation Institute

This year’s PLI Securities Regulation Institute was a source for a lot of useful information and interesting perspectives. Panelists discussed a variety of topics, including climate disclosure (although no one shared any...more

Commissioner Uyeda has some suggestions about the rulemaking process

In remarks this week before PLI’s 55th Annual Institute on Securities Regulation, SEC Commissioner Mark Uyeda shared his views about the disclosure rulemaking process. He observed that, since becoming a commissioner 16 months...more

New Corp Fin intake system for no-action requests related to shareholder proposals

Corp Fin has announced a new intake system for requests from companies for no-action positions from the staff regarding companies’ intentions to exclude shareholder proposals under Rule 14a-8. In the announcement, Corp Fin...more

Will the SEC’s shadow trading theory fall to SCOTUS’s major questions doctrine?

In August 2021, the SEC filed a complaint in the U.S. District Court charging Matthew Panuwat, a former employee of Medivation Inc., an oncology-focused biopharma, with insider trading in advance of Medivation’s announcement...more

SEC approves Nasdaq rule change regarding reverse stock splits

In August, the SEC posted a proposed Nasdaq rule change that would establish listing standards related to notification and disclosure of reverse stock splits. According to the Nasdaq proposal, the volume of reverse splits...more

Fifth Circuit grants Chamber’s petition for review of buyback rule—will the Court ultimately vacate the rule?

Print Friendly, PDF & EmailPrint In May this year, the SEC adopted final rules intended to modernize and improve disclosure regarding company stock repurchases. The rule requires quarterly reporting of detailed quantitative...more

SEC charges SolarWinds and CISO with securities fraud and control failures

You remember the 2020 SolarWinds hack, perhaps one of the worst cyberattacks in history? As NPR described it in 2021, we all regularly receive routine software updates like this one...more

Gensler talks climate with the Chamber

In his introduction to a conversation late last week with SEC Chair Gary Gensler on “Climate Disclosure Developments: The SEC, California, and EU Extraterritoriality,” the President and CEO of the U.S. Chamber of Commerce’s...more

It’s not over till it’s over: Petition filed for rehearing en banc on Nasdaq board diversity rule

As discussed in this PubCo post, on October 18, a three-judge panel of the Fifth Circuit denied the petitions filed by the Alliance for Fair Board Recruitment and the National Center for Public Policy Research challenging the...more

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