News & Analysis as of

Reporting Requirements Securities and Exchange Commission (SEC)

Morrison & Foerster LLP

Reminder: Prepare for EDGAR Next

On September 27, 2024, the U.S. Securities and Exchange Commission (the SEC) adopted amendments to Regulation S-T, resulting in major changes to the Electronic Data Gathering, Analysis, and Retrieval (EDGAR) System for SEC...more

Katten Muchin Rosenman LLP

FINRA Aligns CAT Timestamp Requirements with SEC Relief and Extension to 2030

The Financial Industry Regulatory Authority (FINRA) is updating Rule 6860(a)(2) so that industry members who use time stamps more granular than nanoseconds must continue to truncate (rather than round) those time stamps at...more

Latham & Watkins LLP

FinCEN Postpones New AML Rule for Investment Advisers

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On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more

Proskauer Rose LLP

A Securities and Exchange Commission (SEC) Analisará os Critérios de Elegibilidade para Emissores Privados Estrangeiros (Foreign...

Proskauer Rose LLP on

Empresas latino-americanas com valores mobiliários registrados nos Estados Unidos, ou que pretendem registrá-los, devem ficar atentas. A SEC (Comissão de Valores Mobiliários dos EUA) publicou um “concept release” propondo...more

ArentFox Schiff

Have You Enrolled in EDGAR Next? Enrollment Deadline Approaching

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In September 2024, the US Securities and Exchange Commission (SEC) adopted rule changes to its Electronic Data Gathering, Analysis, and Retrieval (EDGAR) file access and account management system (EDGAR Next), which went into...more

Skadden, Arps, Slate, Meagher & Flom LLP

2026 SEC Filing Deadlines and Financial Statement Staleness Dates

Our guide to 2026 SEC filing deadlines and financial statement staleness dates (including a color-coded calendar) is now available. Public companies should factor in these key reporting deadlines, disclosure obligations and...more

Latham & Watkins LLP

SEC Staff Clarifies Disclosure Expectations for Crypto Asset Exchange-Traded Products

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The Staff highlighted disclosure-related observations and issues identified during reviews of digital asset ETP filings. On July 1, 2025, the Securities and Exchange Commission’s (SEC’s) Division of Corporation Finance...more

Fenwick & West LLP

SEC Division of Corporation Finance Issues Statement on Crypto Asset Exchange-Traded Products

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On July 1, the SEC’s Division of Corporation Finance (Corp Fin) issued a statement regarding Crypto Asset Exchange-Traded Products (crypto asset ETPs). Crypto asset ETPs are investment products that are listed and traded...more

Hogan Lovells

Cross-border SEC spotlight: Key updates for non-U.S. companies – Q2 2025

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Welcome back to our Hogan Lovells Cross-border SEC spotlight: Key updates for non-U.S. companies, a dedicated resource for non-U.S. companies listed or exploring a listing in the United States. This newsletter is published...more

Katten Muchin Rosenman LLP

Texas Court Stays CAT Class Action, But Reporting Must Continue

On July 7, Judge Alan Albright of the US District Court for the Western District of Texas granted the Securities and Exchange Commission’s (SEC) motion to stay a class action by industry groups that challenges the...more

Fenwick & West LLP

SEC's Corp. Fin. Amends CDIs Related to Regulation 13D-G Reporting Rules

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On July 11, the SEC’s Division of Corporation Finance amended 18 Compliance and Disclosure Interpretations relating to Regulation 13D-G, which pertains to beneficial ownership reporting rules.  These amendments bring the...more

Foley Hoag LLP - Public Companies & the Law

SEC Signals Potential Shift in Disclosure Requirements

Recent developments at the SEC highlight the Commission’s focus on reducing disclosure burdens for companies and encouraging public capital formation. SEC Executive Compensation Roundtable - Executive compensation...more

Foley & Lardner LLP

SEC and CFTC Extend Form PF Compliance Date Again

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On June 11, 2025 the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) again extended the compliance date for the most recent Form PF amendments, providing a near four-month reprieve for...more

Davies Ward Phillips & Vineberg LLP

Concept Release: Foreign Private Issuers Under the SEC’s Microscope

Do the U.S. securities law accommodations through the “foreign private issuer” (FPI) construct benefit the intended entities? That’s the fundamental question that the U.S. Securities and Exchange Commission (SEC) is analyzing...more

Morgan Lewis

SEC Requests Public Comment on Changes to the Definition of ‘Foreign Private Issuer’

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On June 4, 2025, the US Securities and Exchange Commission published a concept release to solicit comments on whether and how the definition of “foreign private issuer” (FPI) should be changed. As a result of recent...more

Cooley LLP

Corp Fin Revises Two (And Withdraws One) Legal Proceeding Disclosure CDIs

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A few weeks ago, Corp Fin revised two – and withdrew one – of the Legal Proceedings CDIs under Item 103 of Regulation S-K. These CDI changes are catching up to the reorg of Item 103 that the SEC made five years ago when the...more

Carlton Fields

Five Tips for a New Public Company Director

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How should attorneys advise their clients who are new to a public company board? Where should a corporate secretary start if asked to provide an orientation for a public company board? Former SEC Special Counsel Brian Soares...more

Mayer Brown Free Writings + Perspectives

SEC Statement on Disclosure Best Practices for Crypto Asset ETFs

On July 1, 2025, the staff of the Division of Corporation Finance at the U.S. Securities and Exchange Commission (the “SEC”) issued another in a series of statements regarding crypto assets. This particular statement, titled...more

NAVEX

Watch Out for Hoax Reports to Your Hotline

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We’ve recently been made aware of an increase in anonymous hoax emails and online reports posted to multiple companies through their internal reporting systems. The wording of these posts were identical and alleged violation...more

Ropes & Gray LLP

Ropes & Gray’s Investment Management Update April – June 2025

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Since our prior IM Update, in separate Alerts, we covered (i) the SEC’s decision to remove from its regulatory agenda proposed rulemakings relevant to the investment management industry, (ii) Ropes & Gray’s updated and...more

Troutman Pepper Locke

Foreign Private Issuers: Have You Assessed Your Status Under US Securities Laws? (UPDATED)

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For foreign private issuers registered with the U.S. Securities and Exchange Commission (SEC), there are several filing statuses that affect the content of various disclosures that must be made public. Foreign private issuers...more

Morgan Lewis - Tech & Sourcing

Navigating Evolving Cyber Regulations in the United States

Cyber regulations are crucial for the protection of individuals and businesses and aid in risk minimization; failure to comply with these regulations can result in severe consequences such as financial penalties, legal...more

K&L Gates LLP

SEC Reassesses Foreign Private Issuer Eligibility

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Earlier this month, the US Securities and Exchange Commission (SEC) issued a concept release to solicit public comment on potential changes to the definition of a foreign private issuer (FPI), marking the SEC’s first review...more

Latham & Watkins LLP

Desktop Reference for Foreign Private Issuers With FYE 30 June 2025

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This Latham resource allows FPIs with a 30 June fiscal year-end to stay abreast of key SEC filing dates and financial staleness deadlines....more

Baker Botts L.L.P.

EDGAR Next: Transition to the SEC's New Filing System Before the September Deadline

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Earlier this year, the Securities and Exchange Commission (the “SEC”) introduced a new filing system, referred to as EDGAR Next, which establishes an authentication process for EDGAR filers seeking to make filings with the...more

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