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SEC Seeks Public Comment on Stricter Standards for Foreign Private Issuer (FPI) Reporting

On June 4, 2025, the U.S. Securities and Exchange Commission (SEC) issued a Concept Release soliciting public comments on whether and how to revise the definition of a foreign private issuer (FPI) under the federal securities...more

U.S. SEC Expands Accommodations for Confidential Draft Registration Statements

On March 3, 2025, the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the SEC) issued new guidance, effective immediately, expanding the accommodations available for...more

Back to the Future: SEC Staff Issues Sweeping New Guidance on Shareholder Proposals Mid-Season

On February 12, 2025, the Division of Corporation Finance (Staff) of the U.S. Securities and Exchange Commission (SEC) published Staff Legal Bulletin No. 14M (SLB 14M), rescinding Staff Legal Bulletin No. 14L (Nov. 3, 2021)...more

Reminders for the 2025 Reporting Season

Many companies are in the midst of preparing their year-end Annual Reports on Form 10-K and looking ahead to their annual meeting of shareholders. In addition to changes to rules, regulations and disclosure trends, the...more

Fifth Circuit Court of Appeals Vacates U.S. SEC Share Repurchase Rule

On December 19, 2023, the Fifth Circuit Court of Appeals issued an opinion and judgment vacating (the “Judgment”) the U.S. Securities and Exchange Commission’s (SEC) Share Repurchase Disclosure Modernization rule (the...more

U.S. SEC Adopts Amendments to Beneficial Ownership Reporting Rules

On October 10, 2023, the U.S. Securities and Exchange Commission (the “SEC”) adopted amendments to the rules governing beneficial ownership reporting under Sections 13(d) and 13(g) of the Securities Exchange Act of 1934 (the...more

U.S. SEC Adopts Share Repurchase Disclosure Rules

On May 3, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to its rules that will require additional detail regarding the structure of share repurchase plans or programs and share repurchases by...more

SEC Staff Provides Guidance on Pay Versus Performance Disclosure

On February 10, 2023, the staff of the Division of Corporation Finance (Staff) of the U.S. Securities and Exchange Commission (SEC) published new Regulation S-K Compliance and Disclosure Interpretations (C&DIs) regarding the...more

Preparing for the 2023 Proxy Season

Public companies need to consider recent developments when preparing for the 2023 proxy and annual reporting season. We summarize key regulatory developments, recent guidance, important disclosure considerations and updates...more

U.S. SEC Adopts Amendments to Rule 10b5-1 and Requires Related Disclosures

On December 14, 2022, the U.S. Securities and Exchange Commission (the SEC) adopted amendments to the affirmative defense in Rule 10b5-1(c) under the Securities Exchange Act of 1934, as amended (the Exchange Act), and adopted...more

U.S. SEC Proposes Amendments Regarding Rule 10b5-1 Plans and Related Disclosures

On December 15, 2021, the U.S. Securities and Exchange Commission (the SEC) proposed amendments to the affirmative defense in Rule 10b5-1(c) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), and...more

U.S. SEC Adopts Changes To Streamline And Modernize Financial And MD&A Disclosures

On November 19, 2020, the U.S. Securities and Exchange Commission (SEC) adopted amendments intended to modernize, simplify, and enhance certain financial disclosure requirements in Regulation S-K.[1] The SEC has eliminated...more

U.S. SEC Adopts Changes To Business, Legal Proceeding, And Risk Factor Disclosure Requirements

On August 26, 2020, the U.S. Securities and Exchange Commission (SEC) adopted amendments to the description of business, legal proceeding, and risk factor disclosures that are required pursuant to Regulation S-K. The SEC has...more

U.S. SEC Staff Issues Guidance Regarding On-Going Exchange Act Reporting And Registered Securities Offerings In Light Of COVID-19

On May 4, 2020, the U.S. SEC’s Division of Corporation Finance (the “Staff”) published four “FAQs” relating to the application of the Commission’s March 25, 2020 Order (the “COVID-19 Order”) providing extended deadlines for...more

Guidance For Public Companies On Signatures And Disclosure Considerations In Light Of COVID-19

On March 24, 2020, the staff of the Division of Corporation Finance, the Division of Investment Management, and the Division of Trading and Markets (together, the “Staff”) published Staff Statement Regarding Rule 302(b) of...more

SEC Publishes Proposed Amendments To Exempt Offering Rules

On March 4, 2020, the Securities and Exchange Commission (“SEC”) published Release No. 33-10763, “Facilitating Capital Formation and Expanding Investment Opportunities by Improving Access to Capital in Private Markets” to...more

SEC Adopts FAST Act Amendments to Streamline Disclosure Requirements

On March 20, 2019, the Securities and Exchange Commission (the “Commission”) adopted rule amendments to modernize and simplify certain disclosure requirements in Regulation S-K and related rules and forms. These amendments...more

SEC Issues Guidance on Pay Ratio Disclosure

On September 21, 2017, the Securities and Exchange Commission (the “SEC”) published interpretive guidance (the “SEC Guidance”) to assist public companies in their preparation of the pay ratio disclosure required by Section...more

Repeal of Resource Extraction Disclosure Rule

On February 14, 2017, President Trump approved Congress’ joint resolution to repeal the SEC’s resource extraction disclosure rule. That action effectively brings to a conclusion the SEC’s efforts to implement a resource...more

SEC Re-Proposes Rules for Resource Extraction Issuers Under Dodd-Frank Act

On December 11, 2015, the Securities and Exchange Commission (the “SEC”) proposed rules required under Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). Section 1504 of the Act added...more

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