News & Analysis as of

Comment Period Publicly-Traded Companies

Maynard Nexsen

COSO and NACD Publish a Proposed Corporate Governance Framework

Maynard Nexsen on

On May 27, 2025, the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”), in collaboration with the National Association of Corporate Directors (“NACD”), released and is inviting public comment on an...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

Mayer Brown

CVM Abre Consulta Pública para Discutir o Aprimoramento das Regras de Divulgação de Informações ao Mercado por Companhias Abertas

Mayer Brown on

A Comissão de Valores Mobiliários (CVM) divulgou, em 13 de maio de 2025, o Edital de Consulta Pública SDM n.º 01/25 (Edital), que submete à apreciação do mercado proposta de substituição integral da Resolução CVM n.º 44/21,...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Announces Proposed 162(m) Regulations Defining the Scope of Expanded Covered Employees

On January 16, 2025, the IRS and the Department of the Treasury published proposed regulations relating to Section 162(m) of the Internal Revenue Code. The proposed regulations provide guidance on, and implement, the...more

BCLP

Proxy Advisors Kick-Off the Holiday Season: Glass Lewis Releases ’25 Updates; ISS Seeks Feedback on Proposed ’25 Changes

BCLP on

ISS and Glass Lewis generally publish changes to their proxy voting policies around this time of year. Glass Lewis recently issued its 2025 US Policy Guidelines listing changes and clarifications....more

Wilson Sonsini Goodrich & Rosati

ISS and Glass Lewis Launch Annual Policy Surveys

On August 1, 2024, ISS Governance (ISS) announced the launch of its Annual Benchmark Policy Survey. The survey results will inform ISS’s policy development for 2025 and beyond. For the U.S. market, the survey solicits views...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

WilmerHale

Recent PCAOB Developments for Audit Committee and Companies

WilmerHale on

The Public Company Accounting Oversight Board (PCAOB) has had one of its busiest years in recent memory, including with respect to standard setting, inspections and enforcement. Below is a summary of notable developments that...more

Bass, Berry & Sims PLC

The PCAOB Closes Comment Period on Controversial Proposal to Expand Auditor Responsibility for Legal Compliance

Bass, Berry & Sims PLC on

The Public Company Accounting Oversight Board (PCAOB) recently closed the comment period for its proposal (the Proposal) to significantly increase the responsibility of audit firms to evaluate and disclose a subject public...more

Skadden, Arps, Slate, Meagher & Flom LLP

Comments Raise Concerns About PCAOB’s Proposal To Expand the Scope of Audits and the Role of Auditors

In June 2023, the Public Company Accounting Oversight Board (PCAOB) proposed sweeping amendments to its auditing standards. Comment letters raise serious questions about the consequences of the proposed changes....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

Blake, Cassels & Graydon LLP

ACVM : mise à jour des obligations d’information liée au changement climatique

CONTEXTE - Comme nous l’avons mentionné dans notre Bulletin Blakes d’octobre 2021 intitulé Les ACVM lancent une consultation sur les obligations d’information liée au changement climatique, le 18 octobre 2021, les...more

Blake, Cassels & Graydon LLP

CSA Provides Update on Proposed Climate-Related Disclosure Rules

BACKGROUND - As we reported in our October 2021 Blakes Bulletin: CSA Seeks Comments on Climate-Related Disclosure Rules, on October 18, 2021, the Canadian Securities Administrators (the CSA) issued a notice and request for...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

Mayer Brown Free Writings + Perspectives

SEC Releases Strategic Plan for Comment

The Securities and Exchange Commission recently released for comment a draft strategic plan for fiscal years 2022 to 2026.  In the accompanying message from Chair Gary Gensler, the Chair notes that the strategic plan focuses...more

Mintz

Draft SEC Five-Year Strategic Plan Emphasizes Importance of Climate Disclosures

Mintz on

Recently, the SEC issued its five-year strategic plan for public comment.  This strategic plan covers a wide variety of topics, ranging from adapting to new technology to plans for increasing internal SEC workforce...more

WilmerHale

PCAOB Requests Comment on Draft Strategic Plan

WilmerHale on

The Public Company Accounting Oversight Board (PCAOB) recently released for public comment a draft five-year strategic plan for 2022-2026, setting forth targeted objectives that are oriented around four primary goals: (1)...more

Eversheds Sutherland (US) LLP

SEC moves forward to revise shareholder proposal rule

​​​​​​​On July 14, 2022, the SEC voted 3-2 to propose a rule adopting amendments to Rule 14a-8 (the Proposed Amendments), which requires companies subject to the federal proxy rules to include certain shareholder proposals in...more

Mayer Brown Free Writings + Perspectives

SEC Reopens Clawback Comment Period…Again

On June 8, 2022, the US Securities and Exchange Commission (“SEC”) issued a release (“New Reopening Release“), reopening the comment period on the clawback listing standard rules that it proposed in 2015 (“2015 Proposal“). At...more

Jones Day

U.S. Securities and Exchange Commission Releases Proposed Rule on Climate Risk Disclosure

Jones Day on

As previously reported, on March 21, 2022, the U.S. Securities and Exchange Commission ("SEC") proposed amendments to Regulations S-K and S-X that would require registrants to provide certain climate-related information in...more

Hogan Lovells

SEC propõe novas regras sobre o formato de divulgação de informações sobre mudança climática

Hogan Lovells on

Em 21 de março de 2022, a Comissão de Valores Mobiliários dos EUA (U.S. Securities and Exchange Commission ou “SEC”) propôs suas novas regras de divulgação de informações relacionadas a questões climáticas. As regras...more

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