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An Unasserted Lesson of the SEC’s Yahoo Cyberbreach Enforcement Action

Much has already been written about the SEC’s enforcement action involving Yahoo’s failure to adequately disclose a cyberbreach.1 I am writing about something that the SEC’s announcement and order did not address and...more

Cybersecurity Disclosures: Takeaways From the SEC’s New Guidance

On February 21, 2018, the Securities and Exchange Commission (the “SEC”) issued interpretative guidance to assist public companies in preparing disclosures about cybersecurity risks and incidents.1 The guidance refreshes...more

NYC Comptroller Launches “Boardroom Accountability Project 2.0”: Pushing for More Diversity, Independence and Climate Expertise

On September 8, 2017, New York City Comptroller Scott M. Stringer and the New York City Pension Funds announced the launch of the “Boardroom Accountability Project 2.0.” The goal of Project 2.0 is to make the boards of 151...more

SEC’s Corp Fin Extends Confidential Review of Draft Registration Statements and Provides Guidance

On June 29, 2017, the Securities and Exchange Commission (the “SEC”) announced that the Division of Corporation Finance (the “Division”) will permit all companies to submit draft registration statements relating to initial...more

Guilty Plea Entered for Municipal Securities Fraud

In an April 2016 Quick Study, we reported the criminal action brought by the U.S. Department of Justice against two former municipal officials of the Town of Ramapo, New York for securities fraud involving the issuance of...more

Integration of Private and Public Offerings 2017

I. INTRODUCTION - A. Outline Coverage - This outline reviews the SEC’s interpretations that relate to the integration of private and public offerings and the challenges they impose for the capital formation process....more

Criminal Action is Brought Against Municipal Officials for Fraudulent Bond Disclosure

In what is believed to be the first action of its kind, on April 14, 2016, the U.S. Department of Justice brought a criminal action against municipal officials based on disclosure claims in connection with municipal bond...more

Integration of Private and Public Offerings 2015

I. INTRODUCTION - A. Outline Coverage - This outline reviews the SEC’s interpretations that relate to the integration of private and public offerings and the challenges they impose for the capital formation...more

Locke Lord QuickStudy: Litigation Threat Means Public Companies Should Review Director Compensation Process

Corporate directors are permitted to, and regularly do, set their own compensation. This has not been controversial because boards have typically taken seriously their responsibility to set compensation that is reasonable and...more

Locke Lord QuickStudy: Rights of Creditors and Duties of Directors of Insolvent Delaware Entities Clarified

When companies are in financial distress the question arises as to what rights shift to creditors from shareholders or other equity owners. The Delaware Chancery Court recently addressed this issue in some detail in Quadrant...more

Locke Lord QuickStudy: The Broader Lesson of the El Paso Pipeline Decision

Alternative entities, such as limited partnerships and limited liability companies, have an advantage over corporations because of the greater flexibility to define the terms of the arrangement by contract. ...more

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