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SEC Revises Guidance Affecting Shareholder Activism Under SLB No. 14M and C&DIs

On February 12, 2025, the U.S. Securities and Exchange Commission's ("SEC") Division of Corporation Finance published Staff Legal Bulletin No. 14M ("SLB 14M") relating to the application of the shareholder proposal rules and...more

The Impact of a Second Trump Presidency on SEC Enforcement Priorities

A new presidential administration is likely to bring change across the federal government, perhaps nowhere more starkly than at the Securities and Exchange Commission ("SEC"), which has greatly expanded its enforcement reach...more

SEC v. SolarWinds: Court Rejects SEC Authority Over Cybersecurity Controls and Most Alleged Disclosure Violations

The U.S. District Court for the Southern District of New York dismissed the majority of claims that the Security and Exchange Commission ("SEC") asserted against SolarWinds, including claims that the company's alleged...more

SEC Prevails in Novel "Shadow Trading" Insider Trading Trial

The Securities and Exchange Commission ("SEC") won at trial in its first "shadow trading" case, holding a corporate official liable for insider trading for using nonpublic information about his company's acquisition to trade...more

SEC Pursues Violations of Rule 12b-25: Has "Broken Windows" Returned?

The U.S. Securities and Exchange Commission ("SEC") has charged a group of small companies with making deficient filings on Form 12b-25, harkening back to the SEC's "broken windows" strategy from the last decade....more

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