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SEC enforcement targets beneficial ownership reporting violations - SEC Update

On September 25, the SEC announced that it had initiated and simultaneously settled cease-and-desist proceedings against 23 individuals and companies charged with violations of Exchange Act provisions and SEC rules that...more

Looking ahead to expanded share repurchase disclosure - SEC Update

In May the SEC adopted rule amendments that require reporting companies to disclose in their periodic reports more detailed information about their repurchases of equity securities registered under Section 12 of the Exchange...more

SEC rule amendments require proxy disclosure of executive pay versus performance - SEC Update

On August 25, the SEC adopted rule amendments that require registrants to disclose, in proxy or information statements in which executive compensation disclosure is required, information showing the relationship between...more

SEC proposes significant new cybersecurity disclosure requirements

On March 9, 2022 the SEC proposed rule amendments that would require public companies to report detailed information about material cybersecurity incidents affecting their business and about their cybersecurity risk...more

SEC staff issues sample comments regarding climate change disclosure

On September 22 the SEC’s Division of Corporation Finance published on its website a “Sample Letter to Companies Regarding Climate Change Disclosures,” which it characterizes as an “illustrative letter” presenting “sample...more

Principles matter: SEC amends disclosure rules for business, legal proceedings, and risk factors

On August 26 the SEC adopted far-reaching amendments to Regulation S-K items that govern disclosures on business, legal proceedings, and risk factors in filings under the Securities Act of 1933 and the Securities Exchange Act...more

SEC proposes to amend requirements for disclosure on business, legal proceedings and risk factors

On August 8, the SEC proposed amendments to Regulation S-K to modernize required disclosures on business, legal proceedings and risk factors in Exchange Act and Securities Act filings. The proposed amendments represent the...more

SEC adopts rule amendments under the FAST Act to modernize and simplify disclosure

On March 20, the SEC voted to adopt amendments to Regulation S-K and related rules and forms in accordance with its mandate under the Fixing America’s Surface Transportation Act (FAST Act) to modernize and simplify disclosure...more

SEC brings enforcement action for violation of "equal or greater prominence" requirement in presentation of non-GAAP financial...

The SEC’s Division of Enforcement recently instituted cease-and-desist proceedings against a company for violating Section 13(a) of the Exchange Act and Rule 13a-11 by including non-GAAP financial measures in two of its...more

SEC Issues New Interpretive Guidance on Cybersecurity Disclosures

Prompted by concern over the increase in the risks and frequency of data breach incidents and other cyber-attacks affecting public companies, the Securities and Exchange Commission recently published interpretive guidance to...more

SEC proposes rule amendments under the FAST Act to modernize and simplify disclosure

The SEC recently proposed amendments intended to update, streamline and improve its disclosure framework and to reduce the compliance burden for public companies. The proposed amendments, which are detailed in the proposing...more

SEC Issues New and Revised Guidance on CEO Pay Ratio Rule

On September 21, the SEC and the staff of the Division of Corporation Finance issued new and updated interpretive guidance regarding the CEO pay ratio disclosure required by Item 402(u) of Regulation S-K. The guidance...more

September 1 effective date for exhibit hyperlinks in SEC filings fast approaching

Beginning September 1, public companies will need to comply with SEC rule amendments requiring that reports and registration statements filed on or after that date...more

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