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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

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

Is there an alternative to Scope 3?

As you know, the SEC has proposed a sweeping set of regulations for disclosure on climate (see this PubCo post, this PubCo post and this PubCo post), and we anxiously wait to see what the final rules have in store (obviously...more

Fifth Circuit denies petition challenging Nasdaq’s board diversity rule

On Friday, August 6, 2021, the SEC approved a Nasdaq proposal for new listing rules regarding board diversity and disclosure, accompanied by a proposal to provide free access to a board recruiting service. The new listing...more

ICYMI: column from Matt Levine on SEC Enforcement’s “silly season”

After all the PubCo posts on the avalanche of SEC enforcement cases muscled into the last couple of days before the SEC’s fiscal year end, I thought this column in Bloomberg from Matt Levine might be of particular interest. ...more

SEC approves changes to modernize beneficial ownership reporting [updated]

[This post revises and updates my earlier post primarily to reflect the contents of the adopting release.] Last week, without an open meeting, the SEC adopted rule amendments governing beneficial ownership reporting...more

Is political corruption securities fraud?

You remember Matt Levine’s mantra in his “Money Stuff” column on Bloomberg: “everything is securities fraud”? “You know the basic idea,” he says, a...more

SEC approves changes to modernize beneficial ownership reporting

Yesterday, without an open meeting, the SEC adopted rule amendments governing beneficial ownership reporting under Exchange Act Sections 13(d) and 13(g), updating Reg 13D-G to “require market participants to provide more...more

SEC charges executives with fraudulent revenue recognition practices

As part of its fiscal-year-end enforcement surge, the SEC filed charges against three former executives of Pareteum Corporation, a telecommunications and cloud software company, for fraudulent revenue recognition practices—a...more

SEC charges Newell with misleading disclosure and control failures

In this settled action, the SEC charged Newell Brands and its former CEO with providing misleading disclosure about a prominently featured non-GAAP financial measure—“core sales,” a key NGFM that Newell portrayed as providing...more

NYSE proposes listing standards for a “natural asset company”—what’s that?

The NYSE has proposed to adopt new listing standards for the common equity securities of a “Natural Asset Company,” a new type of public company defined by the NYSE as “a corporation whose primary purpose is to actively...more

NYSE proposes to relax shareholder approval requirements for certain equity sales

On Friday last week, the SEC posted a new NYSE proposed rule change that would “modify the circumstances under which a listed company must obtain shareholder approval of a sale of securities to a substantial security holder,”...more

Corp Fin posts new CDIs regarding pay versus performance

Corp Fin has posted some new CDIs on pay versus performance. In August last year, the SEC finally adopted a new rule requiring disclosure of information reflecting the relationship between executive compensation actually paid...more

Shutdown anyone?

Corp Fin has posted an announcement regarding its plans in the event of a federal government shutdown. The announcement indicates that its activities would be “extremely limited.” (At a hearing yesterday before the House...more

In an enforcement sweep, SEC charges multiple companies and insiders with untimely reporting under Sections 16 and 13(d)

Yesterday, the SEC announced a sweep enforcement action against several insiders and companies for failing to file Forms 4 (Section 16(a) short-swing trading reports) and Schedules 13D and G (reports by beneficial owners of...more

SEC charges GTT with disclosure failures and control violations

This press release announces settled charges brought by the SEC against GTT Communications, Inc., a multinational telecommunications and internet service provider, for failure to disclose material information about...more

Will Congress subject insiders of FPIs to Section 16?

I don’t normally study defense appropriations bills, but the folks at thecorporatecounsel.net blog apparently do. And good thing, too. As they point out, Section 6081 of the new National Defense Authorization Act for Fiscal...more

Investor Advisory Committee recommends human capital management disclosure

On Thursday last week, the SEC’s Investor Advisory Committee voted to approve, with two abstentions, a subcommittee recommendation regarding human capital management disclosure. You probably remember that, in 2020, during the...more

SEC charges CBRE for violation of whistleblower protections

One area where SEC Enforcement appears to have focused its attention recently is whistleblower protections. In this Order against CBRE, Inc., the SEC brought settled charges against the commercial real estate services and...more

Time for EDGAR Next?

Last week, the SEC proposed changes to the EDGAR system designed primarily to enhance EDGAR security, specifically related to EDGAR filer access and account management. In his Statement, SEC Chair Gary Gensler observed that a...more

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