News & Analysis as of

Publicly-Traded Companies Comment Period Regulation S-K

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

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

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

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

Benesch

SEC Proposed Rule-Making - Part I: SEC Proposal on Enhancement and Standardization of Climate-Related Disclosures

Benesch on

In sports, the rules of the game allow for consistent guidance in the face of ambiguity on a given call, as well as allow for comparison across teams, leagues, seasons, and years. SEC Chairman Gary Gensler made this analogy...more

Cooley LLP

SEC (finally) proposes new rules on climate disclosure [UPDATED—PART I]

Cooley LLP on

[This post is Part I of a revision and update of my earlier post primarily reflecting the contents of the proposing release. This post covers background and describes various aspects of the proposal other than the sections on...more

Hogan Lovells

SEC proposes significant new cybersecurity disclosure requirements

Hogan Lovells on

On March 9, 2022 the SEC proposed rule amendments that would require public companies to report detailed information about material cybersecurity incidents affecting their business and about their cybersecurity risk...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

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

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Proposes New Rules for Cybersecurity Risk Management, Strategy, Governance and Incident Disclosure

On March 9, 2022, the Securities and Exchange Commission (SEC) proposed rules that are intended to enhance and standardize disclosures regarding cybersecurity risk management, strategy and governance, as well as cybersecurity...more

BakerHostetler

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

BakerHostetler on

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

WilmerHale

SEC Proposes New Public Company Cybersecurity Disclosure Rules

WilmerHale on

On March 9, 2022, the SEC proposed rules, by a 3-1 vote, that are intended to enhance disclosures about cybersecurity risk management, strategy, governance, and incident reporting by public companies. The proposed rules are...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

Herbert Smith Freehills Kramer

SEC Proposes Changes to Share Repurchase Disclosure Rules and 10b5-1 Plans

The Securities and Exchange Commission (SEC) has issued for comment two separate but related proposed rule amendments regarding share repurchases and 10b5-1 Plans. The comment period will remain open for 45 days after...more

BCLP

2022 Proxy Season - Quick Hits

BCLP on

Considerations for companies planning for next proxy season should include the following: Risk Factors - ..As discussed in our July 13 post, consider current hot topics, including COVID risks, labor market...more

White & Case LLP

SEC Proposes Changes to MD&A Disclosure

White & Case LLP on

The recent proposal by the SEC would eliminate overlapping or unnecessary disclosures and promote a principles-based approach to MD&A.  Background - On January 30, 2020, the US Securities and Exchange Commission (the...more

Goodwin

Financial Services Weekly News: Regulators Propose Easing Volcker Rule Restrictions

Goodwin on

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

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Proposes to Modernize Business, Legal Proceeding and Risk Factor Disclosure Requirements Under Regulation S-K

On August 8, 2019, the Securities and Exchange Commission (SEC) announced proposed amendments to modernize the rules requiring description of business, legal proceeding and risk factor disclosures pursuant to Regulation S-K....more

Foley & Lardner LLP

Reinventing Public Company Disclosure: SEC Requests Public Comment on Regulation S-K

Foley & Lardner LLP on

On April 13, 2016, the U.S. Securities and Exchange Commission (SEC) issued a concept release discussing and requesting public comment on the business and financial disclosure required by Regulation S-K. The concept release...more

WilmerHale

SEC Issues Concept Release on Possible Revisions to Audit Committee Disclosures

WilmerHale on

On July 1, 2015, the Securities and Exchange Commission issued its long-anticipated concept release on Possible Revisions to Audit Committee Disclosures. The concept release notes the important function of the public company...more

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