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SEC Approves December 1st Deadline for NYSE and Nasdaq Clawback Policies: Preparations Companies Should Consider Undertaking Now

On June 9, 2023, the U.S. Securities and Exchange Commission (SEC) approved amendments filed earlier that week by the New York Stock Exchange (NYSE) and The Nasdaq Stock Exchange (Nasdaq) that, among other things, provided...more

Mandatory Executive Compensation Clawback Policies: The Time Is...Soon

On April 24, 2023, the US Securities and Exchange Commission (the SEC) designated Sunday, June 11, 2023, as the date by which it would either approve or disapprove the executive compensation recovery — or clawback — rules...more

When Perquisites Stop Being Fun And Create Serious Liability Risks To An Issuer

Last week, the U.S. Securities and Exchange Commission (“SEC”) brought enforcement actions against a company and its former CEO for failure to adequately disclose certain compensation and related party transactions. The move...more

Rule 701 Update – Increased Threshold for Heightened Disclosure Requirements - July 2018

Effective today, July 24, 2018, the threshold for providing additional disclosure to employees under Rule 701 of the Securities Act of 1933, as amended (Rule 701) is increased from aggregate sales of $5 million in any...more

Rule 701 Update – Increased Threshold for Heightened Disclosure Requirements

On May 24, 2018, President Trump signed into law the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act). While principally aimed at easing the regulatory restrictions applicable to community and...more

Rule 701 Refresher and Updates

The Securities and Exchange Commission (SEC) issued additional guidance in late 2017 to assist companies in complying with the heightened disclosure requirements under Rule 701 of the Securities Act of 1933, as amended (the...more

Planning for the Approaching CEO Pay Ratio Disclosure Requirement

It appears likely that the CEO pay ratio disclosure rule adopted by the Securities and Exchange Commission in 2015 will require companies that are subject to the rule to begin including CEO pay ratio disclosure for 2017...more

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