News & Analysis as of

Proposed Amendments Publicly-Traded Companies Comment Period

Carlton Fields

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

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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

BCLP

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

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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

BakerHostetler

SEC Adopts Amendments to Share Repurchase Disclosures

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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

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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

Mintz

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

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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

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

Goodwin

SEC’s Proposals to Modernize Beneficial Ownership Reporting May Complicate Enforcement of REIT Charter Ownership Limitations

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On February 10, 2022, the U.S. Securities and Exchange Commission (“SEC”) proposed amendments designed to modernize the rules governing beneficial ownership reporting. Section 13 of the Securities Exchange Act of 1934, as...more

Cadwalader, Wickersham & Taft LLP

In Depth: What Can Public Companies Do Now to Prepare for the SEC’s New Proposed Rules on Climate-Related Disclosures?

On March 21, 2022, the U.S. Securities and Exchange Commission (the “SEC”) proposed far-reaching amendments to Regulation S-K and Regulation S-X that would mandate significant additional climate-related disclosures for public...more

Fenwick & West LLP

SEC Proposes New Rules to Enhance Disclosure and Investor Protection Relating to SPACs and Projections – Impact on Target...

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The U.S. Securities and Exchange Commission has proposed new rules and amendments (the Proposed Rules) to enhance disclosure and expand liability in initial public offerings by special purpose acquisition companies (SPACs)...more

Alston & Bird

SEC Proposes Rules to Require Climate-Related Disclosures

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On March 21, 2022, the Securities and Exchange Commission (SEC) proposed rule amendments that would “enhance and standardize” climate-related disclosures. These proposed amendments are the next step in the Biden...more

Keating Muething & Klekamp PLL

Proposed SEC Cybersecurity Rules

On March 9, 2022, the Securities and Exchange Commission (“SEC”) proposed amendments to rules to expand and standardize disclosures regarding cybersecurity risk management, strategy, governance, and incident reporting by...more

Hogan Lovells

SEC proposes modernization of beneficial ownership reporting rules under Exchange Act Section 13

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The SEC recently published its long-awaited proposal to amend Regulation 13D-G under the Exchange Act to modernize the SEC’s requirements for reporting beneficial ownership of securities. The SEC expects that the proposed...more

Eversheds Sutherland (US) LLP

SEC proposes mandatory cybersecurity disclosures

On March 9, 2022, the Securities and Exchange Commission (the SEC) proposed amendments to certain rules regarding cybersecurity disclosure in order to standardize and to enhance disclosures made by public companies that are...more

Mayer Brown Free Writings + Perspectives

SEC Proposes New Rules on Public Company Cybersecurity Disclosures

Background - On March 9, 2022, the U.S. Securities and Exchange Commission (the “SEC”) released proposed amendments (the “Proposed Amendments”) aimed at enhancing and standardizing disclosure relating to cybersecurity...more

Cohen & Gresser LLP

SEC Proposes to Amend Beneficial Ownership Reporting Requirements

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On February 10, 2022, the SEC adopted a proposal to make significant changes in the rules requiring investors to report their ownership of shares of U.S. publicly traded companies. As recommended by some corporate...more

Latham & Watkins LLP

SEC Proposes Stricter Requirements for the Rule 10b5-1 Affirmative Defense

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The Proposal would have a significant impact on current practices surrounding the use of Rule 10b5-1 plans by public companies and insiders. On December 15, 2021, the Securities and Exchange Commission (SEC) issued a set...more

WilmerHale

SEC Proposes Rules to Modernize Share Repurchase Disclosures

WilmerHale on

On December 15, the same day it proposed amendments to Rule 10b5-1 under the Securities Exchange Act of 1934 (Exchange Act) that may blunt the use of the affirmative defense for insider trading, the Securities and Exchange...more

Dorsey & Whitney LLP

SEC Proposes New Amendments to Rule 10b5-1 Trading Plans and Disclosures

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On December 15, 2021, the SEC proposed amendments to Rule 10b5-1, a rule that provides a safe-harbor from liability from the “insider trading” prohibitions under Section 10(b) of the Securities Exchange Act and Rule 10b-5. ...more

Akin Gump Strauss Hauer & Feld LLP

SEC Proposes Amendments to July 2020 Rules Governing Proxy Advisors and Proxy Voting Advice Businesses

On November 17, 2021, the Securities and Exchange Commission (SEC) proposed amendments to its rules governing proxy solicitations. The proposals seek to address concerns by investors and others that the current rules may...more

Goodwin

SEC Proposes Amendments to Rule 10b5-1 Trading Plans

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On December 15, 2021, the U.S. Securities and Exchange Commission proposed amendments to Rule 10b5-1 trading plans, as SEC Chairman Gary Gensler first previewed in June in the wake of increased scrutiny of the plans. A Rule...more

Goodwin

Financial Services Weekly News: Regulators Propose Easing Volcker Rule Restrictions

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In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...more

Mayer Brown Free Writings + Perspectives

SEC Proposes Amendments to MD&A

The Securities and Exchange Commission yesterday voted to propose amendments to the Regulation S-K requirements for Management’s Discussion and Analysis, or MD&A, and also issued agency guidance relating to MD&A. ...more

Bass, Berry & Sims PLC

Key Takeaways from Our Public Company SEC Reporting Webinar

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The Bass, Berry & Sims Corporate & Securities Practice Group recently hosted another in a series of complimentary webinars exploring various public company-related securities law issues. The most recent Securities Law...more

Dorsey & Whitney LLP

OTCQX Proposed Rule Changes

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The OTC Markets Group published this week proposed amendments to the OTCQX Rules for U.S. Companies, U.S. Banks and International Companies. The rules will become effective on December 12, 2019; comments will be accepted...more

Womble Bond Dickinson

SEC Proposes Modernizing Shareholder Proposal Rule

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On November 5, 2019, the U.S. Securities and Exchange Commission (SEC) proposed amendments to Rule 14a-8 under the Securities Exchange Act of 1934 in response to changes in the markets and recent shareholder proposal trends....more

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