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Comment Period Disclosure Requirements Securities and Exchange Commission (SEC)

Mintz - Securities & Capital Markets...

SEC Roundtable on Executive Compensation Disclosure

The Securities and Exchange Commission held a roundtable at the SEC’s headquarters in Washington, DC on June 26, 2025 to discuss possible changes to the Commission’s requirements for executive compensation disclosure...more

McDermott Will & Emery

SEC hosts roundtable on executive compensation disclosure requirements

McDermott Will & Emery on

On June 26, 2025, the US Securities and Exchange Commission (SEC) hosted a roundtable attended by issuers, institutional investors, third-party advisors, and industry groups to discuss potential updates to current executive...more

Stikeman Elliott LLP

SEC Considers Amendments to “Foreign Private Issuer” Definition

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The U.S. Securities and Exchange Commission (“SEC”) recently published a concept release (the “Concept Release”) in which it solicits comments on potential revisions to the “foreign private issuer” (“FPI”) definition. The SEC...more

Troutman Pepper Locke

Executive Compensation Disclosures Are Back on the (Round)table at the SEC

Troutman Pepper Locke on

The SEC announced on May 16 that it will host a roundtable discussion with representatives from public companies, compensation consultants, lawyers, investors, and other stakeholders on the topic of executive compensation...more

Carlton Fields

SEC Solicits Public Comment on Definition of “Foreign Private Issuer”

Carlton Fields on

The Securities and Exchange Commission (SEC) published a concept release on June 4, 2025, seeking feedback on whether the SEC should amend the definition of “foreign private issuer” (FPI). In the release, the SEC asks whether...more

Nutter McClennen & Fish LLP

Nutter Bank Report: April 2024

The CFPB has issued a policy statement that provides an analytical framework for identifying what constitutes an abusive act or practice under the Consumer Financial Protection Act of 2010 (CFPA). The new guidance published...more

Bass, Berry & Sims PLC

Fifth Circuit Requires SEC to Revisit Share Repurchase Disclosure Rules

Bass, Berry & Sims PLC on

On October 31, the U.S. Court of Appeals for the Fifth Circuit (Fifth Circuit) issued an opinion finding that the U.S. Securities and Exchange Commission (SEC) violated the Administration Procedure Act when adopting recent...more

Jones Day

SEC Reopens Comment Period for Rule Proposing New Disclosures for Security-Based Swaps

Jones Day on

The Situation: The Securities and Exchange Commission ("SEC") has reopened the comment period for its proposed rule requiring public disclosure of security-based swap ("SBS") positions that exceed certain thresholds....more

Eversheds Sutherland (US) LLP

ESG in the United States: A complex landscape

The United States is in the process of transitioning ESG disclosure from voluntary, market-led reporting to a regulatory-driven scheme, principally led by the US Securities and Exchange Commission’s (SEC) anticipated (but...more

BakerHostetler

SEC Adopts Amendments to Share Repurchase Disclosures

BakerHostetler on

Rulemaking Background - On Dec. 15, 2021, the SEC proposed amendments to the disclosure requirements regarding purchases of equity securities made by or on behalf of an issuer or any affiliated purchaser....more

WilmerHale

SEC Adopts Amendments to Issuer Repurchase Disclosure

WilmerHale on

On May 3, 2023, in a 3-2 vote, the SEC adopted amendments to significantly increase the disclosure required about issuer repurchases of their equity securities that are registered under the Securities Exchange Act of 1934....more

Wilson Sonsini Goodrich & Rosati

SEC Reopens Comment Period for Proposed Amendments to Beneficial Ownership Reporting Rules

On April 28, 2023, the U.S. Securities and Exchange Commission (SEC) reopened the comment period for its rulemaking proposal, Modernization of Beneficial Ownership Reporting, through the later of 30 days after the reopening...more

Keating Muething & Klekamp PLL

Securities Snapshot: 4th Quarter 2022 - Flurry of Rulemaking from SEC this Winter

During the fourth quarter of 2022, the Securities and Exchange Commission continued its brisk pace of rulemaking across several disclosure initiatives. The Commission reopened the comment period for its share repurchase...more

Mayer Brown Free Writings + Perspectives

SEC Reopens Share Repurchase Disclosure Modernization Comment Period

On December 7, 2022, the US Securities and Exchange Commission (SEC) issued a release (New Reopening Release), reopening the comment period on the share repurchase disclosure modernization rule changes that it proposed on...more

Cooley LLP

SEC reopens comment period (again) for proposal on stock buyback disclosure

Cooley LLP on

Yesterday, the SEC announced that it was reopening (again) the public comment period for its proposed rule on stock buyback disclosure modernization, a rule proposed at the end of 2021. (Remember that the comment period for...more

Holland & Knight LLP

'Tis the Season … to Reopen Public Comment on SEC's Share Buyback Rule Proposal?

Holland & Knight LLP on

The SEC announced on Dec. 7, 2022, a second reopening of the public comment period for its proposed Share Repurchase Disclosure Modernization rule (Rule), first proposed on Dec. 15, 2021. The initial 45-day comment period was...more

Goodwin

SEC Proposes Regulatory Changes to Open-End Fund Liquidity Requirements

Goodwin on

On November 2, 2022, the U.S. Securities and Exchange Commission (“SEC”), by a vote of 3-2, proposed amendments to rules under the Investment Company Act of 1940 that would modify the existing liquidity risk management...more

Herbert Smith Freehills Kramer

SEC Proposes Oversight Requirements for Services Outsourced by Investment Advisers

On Oct. 26, 2022, the Securities and Exchange Commission (SEC) proposed a new rule and rule amendments that would prohibit registered investment advisers from outsourcing various services without first conducting due...more

Holland & Knight LLP

SEC Reopening Comment Period on Several Key Proposed Rules After Technical Error

Holland & Knight LLP on

The SEC on Oct. 7, 2022, reopened the comment period for 11 rule making proposals, one request for comment and eight Self-Regulatory Organization (SRO) matters – all due to a technical error. This glitch likely throws a...more

BakerHostetler

SEC Reopens Comment Period for Certain Comments Submitted Between June 2021 and August 2022, Including on Climate-Related...

BakerHostetler on

​​​​​​​The U.S. Securities and Exchange Commission (SEC) issued a release on Oct. 7, 2022 (Release No. 33-11117, the “Release”) indicating that it was reopening comment periods for 11 proposed rules and a request for comment....more

Orrick, Herrington & Sutcliffe LLP

Comment Period Reopened for Climate and Cybersecurity Proposals, Among Others

On Friday, October 7, 2022, the Securities and Exchange Commission (the “SEC”) reopened the public comment periods for eleven rulemaking proposals and one request for comment due to a technical error that prevented the SEC...more

Alston & Bird

SEC Reopening Comments After Technical Issues

Alston & Bird on

The Securities and Exchange Commission has reopened comments for nearly two dozen proposed rules and other matters. Our Securities Group details the list that includes some controversial rules about cybersecurity, SPACs, and...more

Vinson & Elkins LLP

A Second Chance: The SEC Reopens Comment Periods on Climate, Cyber and Other Rule Proposals in Response to Technical Glitch

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A technological error in the online comment portal on sec.gov has prevented the Securities and Exchange Commission (“SEC”) from receiving comments on twelve rule proposals (the “Affected Proposals”), according to a new SEC...more

Wilson Sonsini Goodrich & Rosati

SEC Reopens Comment Periods for Certain Rulemaking Releases

On October 7, 2022, the U.S. Securities and Exchange Commission (SEC) announced that it will reopen the public comment periods for 11 rulemaking releases and one request for comment due to a technological error that resulted...more

Cooley LLP

The SEC calls “technical glitch”—what happened to your comment letter?

Cooley LLP on

Surprise! The SEC has just reopened a slew of comment periods! Late Friday, the SEC announced that, as a result of a technical error, it had not received a number of electronically submitted comments for at least 11...more

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