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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 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

The SEC's New Proposed SPAC Rules: Death Knell or Much-Needed Guidance?

In 2020 and the first quarter of 2021, the use of special purpose acquisition companies ("SPACs") as a means of taking companies public grew exponentially. SPAC IPOs raised a total of more than $160 billion in that five...more

SEC Threatens to Slap SPACs

The use of SPACs has reached unprecedented levels, but recent pronouncements from the SEC may signal heightened enforcement and litigation risk for SPACs, as well as their sponsors, officers and directors, and auditors. The...more

SEC's Recent Charges Against AT&T Give Renewed Focus to Reg FD

A recent Reg FD SEC enforcement action against AT&T may signal a renewed focus by the SEC that warrants public companies to assess their disclosure processes. On March 5, 2021, the SEC charged AT&T and three executives...more

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