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Cooley LLP

Don’t Forget to Coordinate Your ‘EDGAR Next’ Enrollment for Mutual Insiders!

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We’ve blogged multiple times about how you should prepare to transition to the SEC’s new “EDGAR Next” platform (here’s our latest post). We are now in that transition period where some companies are voluntarily enrolling in...more

Snell & Wilmer

SEC Reporting Update - December 2024

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Insider Trading Policies. As previously discussed in our Winter 2022-2023 Corporate Communicator, the Securities and Exchange Commission (“SEC”) adopted final rules in December 2022 relating to insider trading policy...more

Foley Hoag LLP - White Collar Law &...

SEC to Continue Aggressive Enforcement Efforts in 2024 After Record-Setting 2023

This is the fourth in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

Snell & Wilmer

Corporate Communicator - 2024 Annual Meeting Season

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Clawback Rules. As previously discussed in last Winter’s Corporate Communicator, the Securities and Exchange Commission (“SEC") adopted final rules in October 2022 directing the NYSE and Nasdaq to adopt listing standards that...more

Perkins Coie

Preparing for the 2024 Public Company Reporting Season

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In anticipation of the upcoming reporting season, this Update highlights some of the most significant rule changes, guidance, institutional investor areas of focus, and trends for public companies to consider in preparing...more

BakerHostetler

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

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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

Perkins Coie

Securities Enforcement Forum West 2022: SEC Affirms Aggressive Approach

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On May 12, 2022, senior Division of Enforcement officials from the U.S. Securities and Exchange Commission (SEC) shared the stage with SEC alumni, private practitioners, and other professionals in the field at the Securities...more

Cooley LLP

Blog: Early SEC Enforcement Trends from Chairman Gary Gensler’s First 100 Days

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Gary Gensler was sworn in as chair of the Securities and Exchange Commission on April 17, 2021. Chairman Gensler has promised to strengthen transparency and accountability in the financial markets. Under Chairman Gensler, we...more

Herbert Smith Freehills Kramer

The SEC’s Continued Focus on Cybersecurity Enforcement

On June 14, the Securities and Exchange Commission (SEC) announced a $490,000 settlement with the real estate services provider First American Financial Corporation (First American) for violations of disclosure controls and...more

Burr & Forman

If Your Retirement Plan Holds Employer Securities Keep an Eye on the Jander Case, Part II

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In March 2020, I posted a blog reviewing the evolution of the legal analysis applied to a retirement plan’s holding of “employer securities” under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”)......more

Morgan Lewis

Spotting and Mitigating Enforcement Issues Concerning Cybersecurity-Related Controls and Disclosures

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The growing frequency and public awareness of cyberincidents, evolution of technologies employed by intruders, and proliferation of personal data and infrastructure vulnerable to attack have all contributed to heightened...more

Skadden, Arps, Slate, Meagher & Flom LLP

Inside the Courts – An Update From Skadden Securities Litigators - September 2019

This quarter’s issue includes summaries and associated court opinions of selected cases principally decided between May and August 2019....more

Patterson Belknap Webb & Tyler LLP

SEC Cyber Briefing: Investigation into Wire Fraud and a Look at 2019 Regulatory Initiatives

In our final installment of a three-part series, we look at the U.S. Securities and Exchange Commission’s Investigative Report into the epidemic of wire fraud or “business email compromise,” and then, based on its 2018...more

Patterson Belknap Webb & Tyler LLP

SEC Cyber Briefing: Regulatory Expectations for 2019

Cybersecurity has played an important role in the U.S. Securities and Exchange Commission’s regulatory agenda during the past year. And it’s likely to become even more important in 2019....more

Moore & Van Allen PLLC

SEC Issues Disclosure Guidance as Part of Continued Focus on Cybersecurity

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As cybersecurity attacks have continued to gain prominence as a threat posing critical risk management and compliance challenges for financial institutions, the Securities and Exchange Commission (SEC) has emerged as an...more

BCLP

Securities and Corporate Governance Update – August 2018

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This newsletter discusses noteworthy updates, key regulatory decisions and upcoming compliance reminders. In this edition we review... ...more

Sheppard Mullin Richter & Hampton LLP

You Might Be an Inside Trader If…You Trade on Your Unconfirmed Suspicions of a Cybersecurity Event Prior to Its Public Revelation...

Earlier this year, the SEC released cybersecurity guidance addressing, among other things, the risk of insider trading in the event of a data breach. This risk comes in multiple forms, including the intruders trading on...more

Parker Poe Adams & Bernstein LLP

Don’t Overlook the SEC’s Cybersecurity Governance Guidance

In late February, the SEC approved what it labeled “Guidance on Public Company Cybersecurity Disclosures.” And, sure enough, about three-quarters of its 24 pages focus on the various categories and locations of cybersecurity...more

Cooley LLP

Alert: SEC Issues New Guidance on Cybersecurity Disclosure and Policies

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In February, the SEC announced that it had adopted long-awaited new guidance on cybersecurity disclosure. While the new guidance builds on Corp Fin's 2011 guidance on this topic, it carries more weight because it bears the...more

Orrick, Herrington & Sutcliffe LLP

SEC Commissioners Provide Guidance on Cybersecurity Disclosures After Wave of Record Incidents

The Commission's "new" cybersecurity guidance largely rehashes existing guidance, as is highlighted by objections from two commissioners. At most, the additional qualitative guidance is incremental. It reiterates the need to...more

Eversheds Sutherland (US) LLP

The SEC wants companies to talk about cybersecurity

On February 21, 2018, the Securities and Exchange Commission issued an interpretive release1 providing important guidance to certain registrants on cybersecurity disclosure. Coming on the heels of dozens of high-profile...more

Balch & Bingham LLP

SEC Releases Guidance on Disclosures Concerning Cybersecurity Matters

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On February 21, 2018, the Securities and Exchange Commission (SEC) published a release entitled “Commission Statement and Guidance on Public Company Cybersecurity Disclosures” (“Release”). Designed to assist public companies...more

Stinson - Corporate & Securities Law Blog

SEC Cybersecurity Disclosure and Controls Checklist

In February 2018 the SEC outlined its views with respect to cybersecurity disclosure requirements under the federal securities laws as they apply to public reporting companies. Set forth below is a checklist of items included...more

Fenwick & West LLP

SEC Releases Updated Cybersecurity Guidance

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The U.S. Securities and Exchange Commission on Feb. 21, 2018, issued interpretive guidance on public company cybersecurity disclosures. The new guidance will affect public companies and companies seeking to go public in...more

McGuireWoods LLP

New SEC Cybersecurity Guidance Outlines Disclosure Obligations

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Last week, as previously reported, the U.S. Securities and Exchange Commission (SEC) unanimously voted to approve additional guidance for reporting cybersecurity risks. The release of this guidance underscores the SEC’s...more

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