News & Analysis as of

Regulation S-K Securities and Exchange Commission (SEC) SEC Comment Letter Process

Vinson & Elkins LLP

Insights from the SEC Roundtable on Executive Compensation Disclosure Requirements

Vinson & Elkins LLP on

On June 26, 2025, the U.S. Securities and Exchange Commission (“SEC”) hosted a roundtable on executive compensation disclosure requirements. As noted in prior Insights, the SEC convened the roundtable to evaluate the...more

Goodwin

SEC Adopts New Rules Applicable to SPACs, Shell Companies and Projections

Goodwin on

We previously noted in our March 31, 2022 alert that the U.S. Securities and Exchange Commission (SEC or Commission) held an open meeting on March 30, 2022 to consider proposed rules and amendments regarding special purpose...more

Paul Hastings LLP

Public Company Update: Things to Keep in Mind for the 2024 10-K Season

Paul Hastings LLP on

As we head into year-end, annual reporting season is just around the corner. Over the past 12 months, the SEC has been active on the rulemaking front, resulting in numerous new disclosure obligations for issuers during the...more

Troutman Pepper Locke

SEC Comment Letter Update

Troutman Pepper Locke on

Overview - This article highlights comment letters publicly issued by the Securities and Exchange Commission (SEC) to Real Estate Investment Trusts (REITs) during 2022. The SEC issues comment letters in connection with...more

Sullivan & Worcester

The Status of Two Pending Rules That Would Require Disclosure of Climate Risks

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We discuss the status of two pending federal regulations that would require the disclosure of information concerning greenhouse gas (GHG) emissions and climate-related risks: one proposed by several agencies that would apply...more

BCLP

Have You Updated Your Approach to MD&A?

BCLP on

The next Form 10-K filing for most companies will be their first filing required to comply with the revised Management’s Discussion and Analysis (Item 303 of Regulation S-K) requirements adopted by the SEC in November 2020....more

Bass, Berry & Sims PLC

A Survey of Recent SEC Comment Letters on Human Capital Disclosures

Late last year, the Securities and Exchange Commission (SEC) adopted amendments to modernize the description of business, legal proceedings, and risk factor disclosures that registrants are required to make according to...more

Bass, Berry & Sims PLC

Recent SEC Comment Letter Reveals the Difference Between Prescriptive-Based and Principles-Based Rules

Bass, Berry & Sims PLC on

As we have previously discussed, on August 26, the Securities and Exchange Commission (SEC) voted to adopt amendments to modernize the description of business (Item 101), legal proceedings (Item 103), and risk factor (Item...more

Bass, Berry & Sims PLC

5 Interesting Takeaways from Uber Technologies’ IPO SEC Comments

Bass, Berry & Sims PLC on

While monitoring SEC comment letters, we recently came across the batch of SEC comment letters issued to Uber Technologies, Inc. in connection with its IPO registration statement that was declared effective on May 9, 2019. ...more

Bass, Berry & Sims PLC

Behind the SEC Curtain - Practical Tips for Interacting with the SEC Staff

Bass, Berry & Sims PLC on

I recently presented to the Corporate & Securities Law Committee of the Association of Corporate Counsel (ACC) on the topic entitled “Behind the SEC Curtain: Practical Tips for Interacting with the SEC Staff.” The...more

McDermott Will & Emery

Capital Markets & Public Companies Quarterly: Potential Shift in SEC’s Proxy Access No-Action Policy and Other New Guidance from...

McDermott Will & Emery on

The third quarter of 2016 saw the US Securities and Exchange Commission (SEC) carry forward its momentum from an active second quarter. Recent developments include new SEC Compliance & Disclosure Interpretations (C&DI) and...more

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