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M&A Broker Exemption Update‎

We are updating our March 6, 2023 QuickStudy that discussed the new statutory exemption under section 15(b)(13) of the Securities Exchange Act of 1934 from broker registration that allows unregistered M&A advisers to provide...more

Short Extension of Clawback Policy Deadline Suggests Listed Companies Will Need to Adopt Policies by early August

On April 24, 2023, the SEC extended, for a short time, the deadline for the effectiveness of stock exchange listing requirements under the Dodd Frank Act that will require listed companies to adopt clawback policies for...more

Updating Clawback Policies

The public comment period for the new NYSE and Nasdaq listing standards requiring public companies to have expanded clawback policies ended on April 3, 2023. The new standards will require listed companies to have clawback...more

Syndicated Term Loans and U.S. Securities Laws

Recently, the U.S. District Court in the Southern District of New York held in Kirschner v. J.P. Morgan that a syndicated term loan was not a “security” under several state securities (or Blue Sky) laws. While the ruling did...more

Buybacks: How Companies Can Benefit From Undervalued Stock

Corporate stock buybacks have been prevalent in recent years. However, due to COVID-19 and market volatility, many companies, because they are focused on liquidity and balance sheet strength, have suspended or terminated...more

Third Circuit Clarifies Board Observers Are Not Subject to Section 11 Liability

It is common for investors in venture capital and private equity transactions, and in other investment arrangements, as a condition to their investment, to have rights to appoint board observers when director representation...more

Joint SEC/FINRA Staff Statement Offers Guidance Relating to Broker-Dealer Custody of Digital Asset Securities

On July 8, 2019, the staffs of the Division of Trading and Markets, U.S. Securities and Exchange Commission (“SEC”) and the Office of General Counsel, Financial Industry Regulatory Authority (“FINRA”) released a joint...more

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

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