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Preparing for the 2025 Proxy and Annual Reporting Season: Key Issues and Considerations

For the 2025 proxy and annual reporting season, there are a number of key issues to consider and keep an eye on for further developments as preparations commence. This alert provides an overview of these issues and updates in...more

SEC’s Enforcement Division Continues to Scrutinize Disclosure of Executive Perks

The Securities and Exchange Commission’s (SEC or Commission) Division of Enforcement continues to be laser focused on executive perks and the manner in which they are disclosed by public companies. The SEC is expected to...more

DOJ Brings First-Ever Indictment for Insider Trading Based on Use of a Rule 10b5-1 Plan

On Wednesday, March 1 the Department of Justice (DOJ) announced its first-ever prosecution of an individual for insider trading based on an executive’s use of 10b5-1 trading plans. Terren Peizer, the executive chairman of...more

Disclosing Cryptocurrency Risks: SEC Comment Letter Puts Companies On Notice

The U.S. Securities and Exchange Commission (SEC) Division of Corporation Finance (CorpFin) recently issued guidance (Guidance), including a “Dear Issuer” Sample Letter (Sample Letter) to assist companies in meeting their...more

SEC Proposes Rules on Disclosure of Material Cyber Incidents and Cybersecurity Practices for Public Companies

On March 9, 2022, the SEC released proposed rules intended to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance and cyber incident reporting by companies that are subject to the...more

ESG Disclosures, Congress, and the SEC

The push on environmental, social, and governance (“ESG”) disclosures has increased in the past several years, with these disclosures becoming a particular focus of the Biden Administration, the Securities and Exchange...more

SEC Brings Charges for Cybersecurity Disclosure Failures

On June 14, 2021, the U.S. Securities and Exchange Commission (SEC or Commission) settled charges against an issuer for disclosure controls and procedures violations relating to a cybersecurity vulnerability that exposed...more

SEC Announces Key Priorities and Sees No Slowdown in Enforcement Program

On Oct. 8 and 9, the U.S. Securities and Exchange Commission (“SEC” or “Commission”) presented its annual program, The SEC Speaks in 2020. The Commission touted its virtual enforcement results, particularly in Chairman...more

The SEC Votes to Modernize Regulation S-K

On August 26, 2020, the Securities and Exchange Commission (SEC or Commission) decided in a 3-2 vote to adopt amendments to modernize the disclosure required under Item 101, Description of Business; Item 103, Legal...more

SEC Provides Additional Guidance Regarding COVID-19 Disclosures

On June 23, 2020, the Securities and Exchange Commission’s (SEC) Division of Corporate Finance (CorpFin) issued CF Disclosure Guidance Topic No. 9A, which supplements its earlier COVID-19-related guidance to provide...more

SEC Provides Guidance Regarding COVID-19 Disclosures

On March 25, the Securities and Exchange Commission’s (SEC) Division of Corporate Finance (CorpFin) issued Disclosure Guidance Topic No. 9, which provides its views on disclosure and other securities law obligations companies...more

SEC Offers Expanded Filing Extensions to Public Companies Grappling With the Effects of COVID-19

On March 25, 2020, the U.S. Securities and Exchange Commission (the SEC or Commission) issued an order that updated its March 4 order to extend the conditional exemptions from reporting and proxy delivery requirements for...more

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