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SEC Withdraws Proposed Shareholder Proposal Rules

The SEC has withdrawn proposed rules captioned “Substantial Implementation, Duplication, and Resubmission of Shareholder Proposals Under Exchange Act Rule 14a-8. In conjunction therewith the SEC announced “The Commission does...more

Is There a Simplification of the SEC’s Executive Compensation Rules in the Works?

The SEC announced today that it will host a roundtable on June 26, 2025, to discuss executive compensation disclosure requirements. The roundtable’s agenda and speakers will be disclosed at a later date....more

Corporation Finance Director Speaks to Information Sharing Following Cybersecurity Disclosure

Erik Gerding, Director, SEC Division of Corporation Finance, issued a statement to clear up misconceptions following filing of an 8-K disclosing a cybersecurity incident....more

SEC Director of Corporation Finance Speaks to Cybersecurity Disclosures

Erik Gerding, Director, Division of Corporation Finance, released a statement on the preferred methods to disclose certain cybersecurity incidents.  Mr. Gerding noted “The cybersecurity rules that the Commission adopted on...more

NYSE Updates Shareholder Approval Rule

The NYSE amended its shareholder approval rules to make it easier for listed companies to sell securities to passive existing shareholders without obtaining shareholder approval.  The SEC approved the change on an accelerated...more

SEC Adopts Rules on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure by Public Companies

The SEC adopted final rules requiring registrants to disclose material cybersecurity incidents they experience and to disclose on an annual basis material information regarding their cybersecurity risk management, strategy,...more

SEC Adopts Final Amendments Related to Share Repurchases

The SEC has adopted final amendments requiring disclosures related to issuers’ share repurchases. The amendments will require domestic issuers to...more

Stock Exchanges Publish Proposed Clawback Rules

Both the NYSE and Nasdaq have issued proposed clawback rules in connection with SEC Rule 10D-1. NYSE - The NYSE proposes to comply with Rule 10D-1 by adopting proposed new Section 303A.14 of the Listed Company Manual....more

SEC Adopts Final Rule on 10b5-1 Plans

The SEC has adopted final amendments to Rule 10b5-1 under the Securities Exchange Act of 1934. The amendments: Add new conditions to the availability of the affirmative defense under Exchange Act Rule 10b5-1(c)(1),...more

SEC Issues Final Compensation Clawback Rules

The SEC has adopted rules to require securities exchanges to adopt listing standards that require issuers to develop and implement a policy providing for the recovery of erroneously awarded incentive-based compensation...more

SEC Adopts Pay Versus Performance Disclosure Rules

The Securities and Exchange Commission adopted final rules implementing the pay versus performance requirement as required by Congress in the Dodd-Frank Act. The rules will require registrants to disclose, in proxy or...more

SEC Proposes Changes to Shareholder Proposal Rule

The Securities and Exchange Commission proposed amendments to Exchange Act Rule 14a-8, the shareholder proposal rule, which requires companies subject to the federal proxy rules to include shareholder proposals in their proxy...more

SEC Updates Electronic Filing Requirements

The Securities and Exchange Commission adopted rules and form amendments to: Mandate the electronic filing or submission of certain documents that currently are permitted to be filed or submitted in paper... ...more

SEC Releases Sample Letter to Companies Regarding Disclosures Pertaining to Russia’s Invasion of Ukraine and Related Supply Chain...

The SEC has released an illustrative letter that contains sample comments that the Division of Corporation Finance may issue to companies based on their specific facts and circumstances related to Russia’s invasion of Ukraine...more

Chancery Considers Whether Acceptance of Equity Grant Violated Fiduciary Duties

In Knight v. Miller et al the Delaware Court of Chancery considered, among other things, whether the acceptance of an equity grant violated fiduciary duties. The case was before the Court on a motion to dismiss....more

SEC Proposes Rules to Enhance and Standardize Climate-Related Disclosures

The SEC has proposed rules that would require registrants to provide certain climate-related information in their registration statements and annual reports. The proposed rules would require information about a registrant’s...more

SEC Issues Proposed Rules on Disclosure of Cybersecurity Incidents

The SEC has issued proposed rules on disclosure of cybersecurity incidents.  Specifically, the SEC is proposing to: Amend Form 8-K to add Item 1.05 to require registrants to disclose information about a cybersecurity...more

SEC Proposes to Amend Filing Deadlines for Schedule 13D and 13G

The SEC has proposed comprehensive changes to Regulation 13D-G and Regulation S-T to modernize the beneficial ownership reporting requirements and improve their operation and efficacy....more

The SEC Doesn’t Want Paper Courtesy Copies

Many persons and entities mail or otherwise provide to the SEC Divisions of Corporation Finance and Investment Management paper “courtesy copies” of materials that are filed or submitted via EDGAR, email, online form or other...more

SEC Charges Company for Failing to Evaluate and Disclose Board Member’s Lack of Independence

The SEC announced settled charges against formerly publicly-traded Leaf Group Ltd. for failing to adequately evaluate and disclose in its annual proxy statement the lack of independence of a director and a board committee as...more

ISS Launches New Portal for Proxy Research Data Verification

ISS has announced the planned January 10 launch of a new data verification (DV) portal for U.S. corporations ahead of the 2022 annual meeting season. According to ISS, the launch represents a major expansion of ISS’ current...more

SEC Proposes to Revise Share Repurchase Disclosures

The SEC has proposed amendments to disclosure requirements regarding repurchases of an issuer’s equity securities that are registered under Section 12 of the Securities Exchange Act of 1934. ...more

SEC Proposes Amendments to Rule 10b5-1

The SEC has issued proposed amendments to Rule 10b5-1 and to related forms and disclosures.  The amendments are intended to address perceived abuses of Rule 10b5-1 plans....more

SEC to Again Respond to Rule 14a-8 No-Action Requests

In November, 2021 the SEC Division of Corporation Finance announced it had rescinded Staff Legal Bulletin (“SLBs”) Nos. 14I, 14J and 14K after a review of staff experience applying the guidance in them.  Apparently as a...more

SEC Provides Public Companies Guidance on Upcoming LIBOR Expiration

The SEC issued a statement reminding public companies that on March 5, 2021, LIBOR’s regulator, the Financial Conduct Authority, and administrator, ICE Benchmark Administration, Limited, announced that the publication of the...more

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