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SEC to Consider Changes to “Foreign Private Issuer” Eligibility Criteria

On June 4, 2025, the U.S. Securities and Exchange Commission (the “SEC”) published a concept release soliciting public comment on potential changes to the definition of “foreign private issuer” (“FPI”)....more

Making Waves No Longer: SEC Abandons Climate Disclosure Rule

In a widely anticipated move, the U.S. Securities and Exchange Commission (SEC) has announced that it will no longer defend the agency’s climate disclosure rule issued during the Biden administration. The disclosure rule...more

SEC Staff Issues Guidance on Effectiveness of Form S-3 After Filing Form 10-K but Prior to Filing Part III Information

On March 20, 2025, the U.S. Securities and Exchange Commission (SEC) staff issued a set of Compliance & Disclosure Interpretations (C&DIs). In particular, SEC staff revised or withdrew several C&DIs to allow all Form S-3s,...more

SEC Staff Provides Guidance on Private Offerings to Accredited Investors That Permit General Solicitation and Other Exemptions

On March 12, 2025, the U.S. Securities and Exchange Commission (SEC)’s Division of Corporation Finance (SEC Staff) published new and revised Compliance and Disclosure Interpretations (C&DIs) regarding private offering...more

SEC Publishes Revised C&DI Related to Lock-Up Agreements in Business Combinations and New C&DIs Related to Tender Offers

On March 6, 2025, the U.S. Securities and Exchange Commission (SEC) published (1) a revised Compliance and Disclosure Interpretation (C&DI) regarding lock-up agreements in business combinations and (2) five new C&DIs...more

SEC Announces Measures to Facilitate Capital Formation

In March 2025, the U.S. Securities and Exchange Commission (SEC) announced that it is expanding the accommodations available for issuers that submit draft registration statements for nonpublic review. The SEC’s Division of...more

SEC Seeks to Pause Litigation Over Climate Disclosure Rule

Earlier this week, Mark Uyeda, the Acting Chairman of the U.S. Securities and Exchange Commission (SEC), began the process of unwinding that agency’s final climate disclosure rule enacted during the Biden administration. In a...more

Nasdaq Diversity Rule Deemed Unenforceable By 5th Circuit

On December 11, 2024, the U.S. Court of Appeals for the 5th Circuit, sitting en banc, ruled that The Nasdaq Stock Market LLC (Nasdaq) cannot enforce previously adopted listing rules requiring Nasdaq-listed companies to have...more

Making Waves: The SEC Publishes Final Climate Disclosure Rules

Key Points - On Wednesday, March 6, 2024, the SEC in a 3-2 vote adopted “The Enhancement and Standardization of Climate-Related Disclosures for Investors” (Final Rule). The Final Rule will require public companies to...more

SEC Adopts Final Rules on SPACs, Shell Companies and Projections

The Securities and Exchange Commission (SEC) recently adopted final rules (available here; also see the fact sheet and press release) representing significant changes to  special purpose acquisition companies (SPACs), shell...more

New SEC C&DIs Relating to Rule 10b5-1 Amendments

As discussed in our prior publication (found here), the Securities and Exchange Commission (SEC) adopted amendments on December 14, 2022, regarding Rule 10b5-1 insider trading plans and related disclosures. On May 25, 2023,...more

SEC Adopts Amendments Regarding Share Repurchase Disclosure

On May 3, 2023, the Securities and Exchange Commission (SEC) adopted amendments requiring disclosure related to issuers’ share repurchases. Item 703 of Regulation S-K currently requires issuers to disclose information about...more

SEC Amendments Regarding Rule 10b5-1 Insider Trading Plans and Related Disclosures

On December 14, 2022, the Securities and Exchange Commission (SEC) adopted amendments regarding Rule 10b5-1 insider trading plans and related disclosures. The amendments aim to strengthen investor protections concerning...more

SEC Adopts Final Clawback Rules

On October 26, 2022, the U.S. Securities and Exchange Commission (SEC) adopted long-awaited final rules implementing the “clawback” provisions of Section 954 of the Dodd-Frank Wall Street Reform and Consumer Protection Act....more

Sea Change: The SEC Makes Waves with New Proposed Climate Disclosure Rules

Key Points - On Monday, March 21, 2022, the SEC in a 3-1 vote proposed amendments to require public companies to provide certain climate-related information in their registration statements and annual reports. The...more

SEC Approves New Nasdaq Rules Covering Board Diversity Disclosures

On Friday, August 6, 2021, the U.S. Securities and Exchange Commission (SEC) issued an order (the “Order”) approving certain rule changes proposed by The Nasdaq Stock Market LLC (“Nasdaq”), which will require companies listed...more

SEC Votes to Adopt Rule Amendments to Modernize Disclosures of Business, Legal Proceedings, and Risk Factors Under Regulation S-K

On August 26, 2020, the Securities and Exchange Commission (SEC) voted to adopt amendments that modernize the description of business (Item 101), legal proceedings (Item 103) and risk factor disclosures (Item 105) that...more

SEC’s Division of Corporation Finance Provides Updated Guidance on Disclosure Considerations Regarding Operations, Liquidity and...

On June 23, 2020, the Division of Corporation Finance (“Division”) of the Securities and Exchange Commission (SEC) provided additional guidance (“Topic No. 9A”) regarding disclosures about operations, liquidity and capital...more

OCA Statement on the Continued Importance of High-Quality Financial Reporting for Investors in Light of COVID-19

On June 23, 2020, the Office of the Chief Accountant (OCA) of the Securities and Exchange Commission (SEC) issued another statement on the importance of high-quality financial reporting in light of the impact of, and...more

SEC Staff Issues Guidance Regarding Requirement to Submit Annual Reports to SEC Under Exchange Act Rules 14a-3(c) and 14c-3(b),...

On November 2, 2016, the Staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (SEC) issued guidance regarding the submission of annual reports by registrants to the SEC under Exchange...more

SEC Adopts New Rules Requiring Disclosure of Resource Extraction Payments

On June 27, 2016, the Securities and Exchange Commission (SEC) adopted new rules requiring certain producers of oil, natural gas and minerals to publicly disclose information regarding payments to the U.S. federal government,...more

SEC Approves Nasdaq Rule Change to Require “Golden Leash” Disclosure

On July 1, 2016, the Securities and Exchange Commission (SEC) approved a rule change proposed by The Nasdaq Stock Market LLC (Nasdaq) to require Nasdaq-listed companies to publicly disclose compensation or other payments made...more

SEC Adopts Rules Implementing FAST Act Provisions

The U.S. Securities and Exchange Commission (SEC) recently approved interim final rules implementing two provisions of the Fixing America’s Surface Transportation (FAST) Act that ease the financial statement disclosure...more

JOBS Act 2.0 – New FAST Act Legislation Signed into Law to Facilitate Capital Formation

On December 4, 2015, President Obama signed into law the Fixing America’s Surface Transportation Act (the “FAST Act”). While the legislation is aimed at providing long-term funding certainty for surface transportation, it...more

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